Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2572

 1                          Friday, 16 November 2001

 2                          [Open session]

 3                          [The accused entered court]

 4                          [The witness entered court]

 5                          --- Upon commencing at 9.29 a.m.

 6            JUDGE HUNT:  Call the case, please.

 7            THE REGISTRAR:  Case number IT-98-32-T, the Prosecutor versus

 8    Mitar Vasiljevic.

 9            JUDGE HUNT:  Yes, Mr. Domazet.

10            MR. DOMAZET:  Thank you, Your Honour.

11                          WITNESS:  MILOJKA VASILJEVIC [Resumed]

12                          [Witness answered through interpreter]

13                          Examined by Mr. Domazet: [Continued]

14       Q.   Good morning, Mrs. Vasiljevic.

15       A.   Good morning.

16       Q.   May we continue where we left off yesterday afternoon.  If you

17    recall, we were discussing the subara or fur hat and the hat, the sesir.

18    The subara or fur hat you said was worn by the man named Mitar Knezevic,

19    do you remember saying that?

20       A.   Yes.  I know what a subara looks like, and I also know what a hat

21    is.  The subara is the Serb hat, cap, that people from our parts wear.

22       Q.   One possibility was that you could draw what it looked like.  Do

23    you think that you could do that?  Could you draw what it looks like?

24    Have you got a piece of paper in front of you?

25       A.   No.

Page 2573

 1            JUDGE HUNT:  And something to draw with.

 2            MR. DOMAZET: [Interpretation]

 3       Q.   Would you please in the upper part or on the left-hand side, shall

 4    we say, in the left-hand corner, would you draw what a subara looks like,

 5    what you think it looks like, and on the right, a hat or sesir.

 6       A.   Well, the subara can be like this or it can be shorter.  You can

 7    raise it up or make it shorter whereas a hat has a rim.  I don't know

 8    actually how I'm going to do this.

 9            JUDGE HUNT:  I had hoped that this would be done overnight, I'm

10    afraid, Mr. Domazet.

11            MR. DOMAZET:  Yes.

12       A.   I don't really know.

13            MR. DOMAZET: [Interpretation] I haven't had any contacts with

14    Mrs. Vasiljevic for understandable reasons.  She has taken the solemn

15    declaration.  Perhaps we could have told her at the end of yesterday's

16    session to have a go, but I think that the explanation that she has given

17    by saying that the hat or sesir has a rim whereas the subara type does not

18    have a rim is something which is satisfactory for our purposes and that we

19    can agree that one has a rim whereas the other hasn't.

20       A.   Perhaps you were thinking of the Russian-type hat with the ear

21    flaps, but that's quite different.  It's not that type of subara, the

22    Russian type with the ear flaps, but you can raise it up and push it

23    inside and it then can be short like a very short cap, hat.

24            JUDGE HUNT:  Mr. Domazet, provided that we agree that the word

25    "rim" is the same as "brim," that the subara does not have a brim, then I

Page 2574

 1    think that is sufficient.

 2            THE INTERPRETER:  Interpreter's note, sorry, Your Honour, "brim."

 3            JUDGE HUNT:  Yes.  Well, then we are agreed.  Thank you,

 4    Mr. Domazet.  I thought that we had been asked for it to be done overnight

 5    but if it wasn't clear, then it's my fault.  But we've got, I think now, a

 6    clear picture of what it is to which she is referring.

 7            MR. DOMAZET: [Interpretation]

 8       Q.   Mrs. Vasiljevic, can you describe for us, to the best of your

 9    recollection, what the hat looked like that your husband wore from time to

10    time at that time?

11       A.   The hat that Mitar wore sometimes was smaller.  It was a hunting

12    hat, because his father was a hunter and had the hat.  And so sometimes

13    Mitar would use a smaller hat like that.  It was a darker colour and with

14    a small brim, narrow brim.

15       Q.   So if I understand you correctly, Mrs. Vasiljevic, it is a hat

16    with a small brim, of smaller dimensions, that is, and the colour was

17    dark; is that right?

18       A.   Yes.

19       Q.   Can you remember - and I'm speaking of that time and that year,

20    1992 - whether, at that period which we have discussed at length, your

21    husband, Mitar, wore a coat?

22       A.   Mitar didn't own a coat, nor did he ever wear a coat.

23       Q.   Do you mean he didn't wear a topcoat or coat at all?

24       A.   No.  He didn't have a topcoat, nor did he wear one ever.

25       Q.   Throughout the time that you have been married to your husband,

Page 2575

 1    did he ever wear a moustache?

 2       A.   Never.  He never wore a moustache, ever.

 3       Q.   Did he ever have a beard?

 4       A.   No, he never had a beard.

 5       Q.   Did he have a nickname of any kind?

 6       A.   No, he never had a nickname.

 7       Q.   Mrs. Vasiljevic, can you tell me who your kum was at the wedding

 8    ceremony when you married Mitar, that is to say, the first witness or the

 9    main kum, at your wedding ceremony?

10       A.   Our first witness and main kum at my wedding was Luka Lukic.

11       Q.   Mrs. Vasiljevic, did you hear about a wedding that took place

12    after the war at which Milan Lukic was the main witness, or rather, kum?

13    So my question to you is:  Did you hear about a wedding of that kind?

14       A.   No, I didn't.

15       Q.   Shall I try -- let me put it this way:  Do you know somebody

16    called Rade Vasiljevic?

17       A.   Yes, I do.  I know Rade Vasiljevic.

18       Q.   Did his son get married in recent years?

19       A.   Yes.  Yes, his son did get married, and he had a wedding.

20       Q.   Were you personally invited to attend that wedding?

21       A.   No, I wasn't.  My husband attended the wedding, and so did my

22    children.

23       Q.   Thank you.  Mrs. Vasiljevic, when you spoke about the house you

24    lived in, you spoke about the house which your father-in-law, that is to

25    say, Mitar's father, bought, which you lived in, and you mentioned another

Page 2576

 1    house as well which, in the 1980s, you started building.  Could you tell

 2    me now, please, whether, and if so, when, you ever completed the house for

 3    it to be habitable at all.

 4       A.   Yes, we did complete the house in 1999, and SFOR lived in the

 5    house.  They moved in, not us.

 6       Q.   So when you had made the house habitable, you did not move in, but

 7    the SFOR moved in and they rented the place from you as tenants; is that

 8    right?

 9       A.   Yes, that's right.  SFOR members lived in our house.

10       Q.   Who drew up a contract with them about the lease and rent of the

11    house?

12       A.   Mitar did.

13       Q.   Do you know whether the money that was deposited by way of rent,

14    was it a deposit to cover several months of rent in advance, or not?

15       A.   Yes.  They paid in advance for us to be able to finish what was

16    left to do so that they could move in.

17       Q.   So do I understand you correctly:  You received the money in

18    advance to be able to complete the construction that hadn't been completed

19    so that they could move in?

20       A.   Yes, that's right, for us to be able to complete the house and

21    furnish it so that they could move in.

22            JUDGE HUNT:  Both of you, please pause.  You are both coming in on

23    top of the translation.

24            MR. DOMAZET: [Interpretation]

25       Q.   If you count back from the arrest of your husband, how many months

Page 2577

 1    before that did SFOR come to rent your house, in addition to the old house

 2    that you yourselves lived in?  How long before the arrest was that?

 3       A.   SFOR took up residence, I think, seven months before Mitar was

 4    arrested, seven months prior to Mitar's arrest.

 5       Q.   During that time, during those seven months, as you say,

 6    throughout that time, was Mitar there and did he live in the house next

 7    door to the SFOR building, the -- yes.

 8       A.   Yes, we all lived there, Mitar too.  All of us were there.  While

 9    SFOR was renting out our place, we were next door, all of us living in the

10    house next door.

11       Q.   Apart from living in the house next door, did he have any special

12    relationships with the soldiers living there, that is to say, did he

13    socialise or see them?

14       A.   Yes, he did.  They were all friends.  Mitar socialised, our

15    children did.  We would go over to them when they had a birthday

16    celebration, a birthday party, or their Christmas or New Year, and they

17    would come to our place.

18       Q.   I assume that the SFOR people changed from time to time.  Did they

19    know that your husband's name was Mitar Vasiljevic?

20       A.   Yes, of course they did.  All of them knew who we were and what we

21    were and they all knew Mitar.  Of course they did, yes.

22       Q.   Did anybody ever, of any official organs of Republika Srpska or of

23    SFOR tell your husband that there was the -- he was a suspect and that

24    investigations were underway with respect to what had been going on during

25    the war conflict and that he was a suspect in those investigations?  Did

Page 2578

 1    anybody ever tell you that, anybody official in an official capacity?

 2       A.   No, never.  Nobody ever told me anything.

 3       Q.   Since 1992 up until the beginning of the year 2000 when Mitar was

 4    arrested, did Mitar ever change his residence, place of residence at all?

 5       A.   No, never.  Mitar never changed his place of residence.  He was

 6    always there.  He was never absent, not a single night.

 7       Q.   When I say "changed residence," did he spend a period of time

 8    outside Visegrad, that's what I mean, and outside the house in Vojvode

 9    Stepe Street that you lived in all together?

10       A.   No.  Mitar never changed his place of residence where he lived.

11       Q.   In talking to you, did he ever express any qualms or doubts that

12    he might be arrested or that any proceedings might be initiated against

13    him?  Did he ever express any qualms of that nature?

14       A.   No, never.  He never had any doubts along those lines, never

15    suspected anything like that.

16       Q.   Were you, Mrs. Vasiljevic, present when he was arrested, and what

17    were your reactions to that arrest?

18       A.   No, I wasn't at home at the time.  I was working.  My daughter

19    came sometime around half past 3.00.  Usually Mitar would go into town and

20    come back home, he would do this several times, and she said, "Well, daddy

21    hasn't come home yet.  I don't know where he is."

22       Q.   In answer to some of my questions, you said that you worked as a

23    tradesperson, salesperson in Visegrad and in several places around

24    Visegrad; is that right?  Did you work actually in villages inhabited

25    either only by Muslims or where the majority of the population were

Page 2579

 1    Muslims because the surrounds of Visegrad are -- is made up of villages of

 2    different ethnicity?

 3       A.   Yes, I did.  I worked in villages where the majority population

 4    were Muslims, and also in villages with a mixed population where there

 5    were Muslims and Serbs.  I worked in Crnca where there was not a single

 6    house, they were all the Muslim houses, and I worked in town too.

 7       Q.   Apart from Crnca which you said was an exclusively Muslim village,

 8    could you perhaps remember another village where there were mostly Muslims

 9    where you worked as a salesperson?

10       A.   Yes, I worked in Dusce, that's another one, mostly Muslims living

11    in that village.

12       Q.   You mentioned working in Prelovo, is Prelovo a mixed village with

13    mixed inhabitants or is it a Serb village with Serb inhabitants?

14       A.   Yes, I did work in Prelovo.  There are Serbs living there, but I

15    think that more of the -- most of the inhabitants are Muslims.

16       Q.   When you worked in those villages, how did you personally get on

17    with the villagers who belonged to a different ethnic group or rather the

18    Muslims in those villages?

19       A.   I had excellent relations with them.  Nobody ever said anything to

20    me and I didn't say anything -- I didn't have any problems at all.

21       Q.   That means, I take it, that you never had any problems.  Did they

22    have any problems with you, that is to say, did anybody complain to the

23    company that employed you about your work or anything like that?

24       A.   No, never, never.  Nobody ever complained, no.

25       Q.   During all that time, did any of the Muslims ever complain to you

Page 2580

 1    about your husband Mitar, about his conduct towards Muslims which was

 2    not -- which they thought was not in order or anything like that, not

 3    proper?

 4       A.   No, nobody ever complained to me about Mitar.

 5            MR. DOMAZET: [Interpretation] Thank you, Mrs. Vasiljevic.  I have

 6    no further questions for you.

 7            JUDGE HUNT:  Cross-examination, Mr. Groome.

 8            MR. GROOME:  Thank you.

 9                          Cross-examined by Mr. Groome:

10       Q.   Mrs. Vasiljevic, while we are talking about Prelovo, you said that

11    there are mostly Muslims there.  Do you mean that today, Prelovo is still

12    comprised mostly of Muslims or did you mean that back in 1992?

13       A.   No, in 1992, they were Muslims.  Today, it's a Serb-populated

14    village because they haven't returned.

15       Q.   Where did the Muslims go?

16       A.   I don't know.

17       Q.   When did they leave?

18       A.   Probably they left when the war broke out.

19       Q.   Mr. Domazet has asked you a number of questions about the SFOR

20    personnel living in your house.  They were French, weren't they?

21       A.   Yes.  Yes, they were French, and my children went to learn French

22    with them.  They gave them French classes.

23       Q.   And they remained in that house up until the time that your

24    husband was arrested; correct?

25       A.   Yes, yes.

Page 2581

 1       Q.   How long after your husband had been arrested did they leave?

 2       A.   When my husband was arrested, and when I came home, they weren't

 3    there.

 4       Q.   So from the moment your husband was arrested, they no longer lived

 5    in your house; is that correct?

 6       A.   That's right.  They were no longer there.

 7       Q.   Mrs. Vasiljevic, surely you must realise at this stage that those

 8    men were there to arrest your husband, and lived in your house for six

 9    months in order to try to find out information about Milan Lukic.

10    Certainly that must have occurred to you by this stage, no?

11       A.   No.  No, I didn't know anything about what they were doing there.

12    All I knew was that they lived in my house.  I have no idea why they lived

13    there.

14       Q.   You are aware now that the indictment against your husband was a

15    sealed indictment; correct?

16       A.   I learned that later on when my husband left and when all this

17    happened.

18       Q.   But you now know that the indictment against your husband was in

19    existence during the time that those French SFOR soldiers were living in

20    your house.  You now realise that to be true, don't you?

21       A.   I know that now, but I didn't know that then.

22       Q.   You said yesterday - and you were referring to Milan Lukic - you

23    said:

24            "I heard that he took part in house burning, but I don't know.  I

25    wasn't there.  I didn't see it.  Ugly things, but I don't remember what

Page 2582

 1    were all the things that he did."

 2            Can I ask you:  When did you first learn that Milan Lukic had been

 3    involved in a house-burning?

 4            JUDGE HUNT:  Yes, Mr. Domazet.

 5       A.   [No interpretation]

 6            JUDGE HUNT:  Just a moment.

 7            MR. DOMAZET: [Interpretation] Your Honour, if I remember

 8    correctly, these are the words which the witness did say, but with respect

 9    to another person, another person altogether, and not Milan Lukic.

10            THE WITNESS: [Interpretation] Yes.  Yes.  I didn't say that it was

11    Milan Lukic.  I said that it was Mitar Knezevic.  That's what I heard.  I

12    didn't see it, but that's what I said.

13            MR. DOMAZET: [Interpretation] We can check in the transcript.

14            THE WITNESS: [Interpretation] Not Milan Lukic; Mitar Knezevic.

15            JUDGE HUNT:  That's certainly my recollection.

16            MR. GROOME:  Let me clear that up with the witness.

17            JUDGE HUNT:  No, no.  That is my recollection of what she said.

18    She was talking about Mitar Knezevic.  There's no doubt about that,

19    because I remember Mr. Domazet trying very hard and for a very long time

20    to get some further information about him from her.

21            MR. GROOME:  Then I apologise for my misinterpretation of the

22    record and I'll proceed.

23            JUDGE HUNT:  Yes.

24            MR. GROOME:

25       Q.   Can you tell us when it was that you first heard that this person

Page 2583

 1    named Mitar Knezevic had been involved in a house-burning?

 2       A.   I don't know.  I don't know when he became involved.  Later on,

 3    stories started circulating around the town about him, and there were

 4    newspapers, but I don't know when he became involved.

 5       Q.   And that would have been in 1992?

 6       A.   I think it was 1992.

 7       Q.   And do you remember who told you that Mitar Knezevic had been

 8    involved in a house-burning?

 9       A.   No, no, no.  I don't.  I don't.  I read about it, but I don't

10    know.

11       Q.   Now, there were two house-burnings covered in the media from

12    Visegrad.  One was on Pionirska Street and one was in Bikavac.  The rumour

13    or the story that you heard regarding Mitar Knezevic, did it specify which

14    house he was involved in the burning of?

15       A.   Well, the rumour went that houses had been set on fire.  There

16    were different stories.  I do not know which newspaper or who is it that

17    wrote that it was Mitar Knezevic.

18       Q.   Well, we know from other testimony in this case that many houses

19    were set on fire.  I understood you to mean yesterday that people died in

20    the house-burning that you were referring to.  Is that correct?

21       A.   I don't know who died, who was there.

22       Q.   But the house-burning that you were referring to yesterday, was

23    that a house-burning in which you believe people died?

24       A.   I only read about it in the newspaper afterwards.  I read all

25    sorts of things.  Otherwise, I don't know anything, because I wasn't

Page 2584

 1    present there.

 2       Q.   But I'm just trying to understand whether or not it was your

 3    belief that people died in the fire.  Was it your belief or was it not

 4    your belief?

 5       A.   Well, I guess so.  I have no idea.  I don't know.

 6       Q.   You've told us that your husband owned one hat; is that correct?

 7       A.   He didn't wear it all the time.  At times, now and then, he would

 8    put on a smallish hat, but he didn't wear it always.

 9       Q.   Did he only own one hat?

10       A.   Well, he didn't have any hats.  At times he would borrow it from

11    his father and wear it.  He himself didn't have any.

12       Q.   So he had no hats, and the only hat that you ever saw him with was

13    his father's hat; is that correct?

14       A.   Yes, now and then.

15       Q.   Did you ever see him with a military-type hat?

16       A.   No.  I don't even know what a military-type hat looks like.

17       Q.   And certainly, you being his wife, if he had such a hat, would

18    have seen it hanging in the house or have seen him wearing it at some

19    point; correct?

20       A.   I never had it, nor did I ever see a military hat.

21       Q.   Now, you said that nor did your husband own a coat; is that

22    correct?

23       A.   He had a heavy coat but not a light topcoat, not a raincoat.

24       Q.   So he had a heavy coat, as you're describing it now.  Was that the

25    only coat that he had?

Page 2585

 1       A.   I don't know.  Which do you mean?  A jacket, a short coat; or a

 2    long one, a topcoat?  Yes, he had both of these things, but he never had a

 3    light coat, a light, long coat.

 4       Q.   So you're telling us that your husband had two coats; is that

 5    correct?

 6       A.   Well, of course he had a number of jackets.  He had a number of

 7    jackets.  Coats, topcoats, no, he never had that one.

 8       Q.   And can you tell us the number of jackets that your husband had?

 9       A.   Well, I don't know.  I mean, he worked as a waiter, so of course

10    he had suits and he had jackets, and when he worked, he would have to wear

11    a black suit.

12       Q.   Let's just confine ourselves to out door coats, something that

13    somebody would wear over their clothing when they go outside.  How many

14    of -- how many jackets did he have meeting that description?

15       A.   No, never.  He didn't have a mantle or any topcoat, anything that

16    he would wear over his jacket.

17       Q.   Can you tell us what he would wear outside when it was raining?

18       A.   Well, he wore the olive-green/grey uniform and his clothes.

19       Q.   But he had no protection from the rain?

20       A.   No.  Well, I mean, of course he had an umbrella.  I don't see what

21    else.

22       Q.   And in the wintertime, when it gets cold in Visegrad, what kind of

23    jacket or coat does he wear then?

24       A.   Well, of course he must have had -- of course he had a winter

25    jacket, a heavy jacket.

Page 2586

 1       Q.   And what was the colour of that jacket?

 2       A.   Still he has it.  Well, it's a relatively light colour, short.

 3       Q.   When you say "short," to what portion of his body does the coat

 4    reach?

 5       A.   Well, it's like this, just like any other jacket.  Just like a

 6    jacket, not a long one.  Just a short -- like this.  Like this, you know.

 7    A jacket.

 8       Q.   You're describing the jacket that you have now; correct?  You're

 9    pointing to your jacket.  Do you mean it's the same length as the jacket

10    you have on here in Court?

11       A.   Yes, thereabouts.  Perhaps even shorter than what I have on.

12            JUDGE HUNT:  Can you describe what the witness is wearing, then?

13    I'm afraid I've not seen the length of her coat.

14            MR. GROOME:  Yes, Your Honour.

15       Q.   The coat that you're wearing comes just below your waist;

16    correct?  The coat that you're wearing now, it comes just below your

17    waistline; isn't that correct?

18       A.   No, no, no.  His jacket is shorter than the one that I'm wearing

19    now.  This one is longer than his jacket is.

20       Q.   Would his jacket come to his waistline?  Is that what you're

21    trying to describe for us?

22       A.   Well, yes.  I'd say just an ordinary -- just an ordinary jacket,

23    not a long one.  Like this, relatively short.

24       Q.   Now, yesterday you told us that one day your husband came home and

25    he was quite distraught and he kept talking about a colleague and his

Page 2587

 1    colleague's son, and you told us, if I remember correctly, that that

 2    day -- on that day you had a birthday party for your son Nikola; is that

 3    correct?

 4       A.   No, no, no, you didn't get me right.

 5       Q.   Did you have a birthday party for your son Nikola around that day?

 6       A.   No, no, no.  You did not understand what I was saying at all.

 7    What I said that Mitar's colleagues would come for Nikola's birthday, and

 8    Nikola's birthday was in August.  It wasn't that day when Mitar was so

 9    distressed.

10       Q.   And you've told us a bit about Serbian custom.  Is it Serbian

11    custom to, on a child's birthday, have a party and invite friends of the

12    family to that party?

13       A.   Yes.  Of course I invite my colleagues, Mitar invites his, and we

14    were preparing this -- when we had this party.  There must have been about

15    10 of Mitar's colleagues and my colleagues, and all our close and distant

16    relatives.

17       Q.   While we're discussing Serbian custom, could you give me an idea,

18    when would a typical Serbian family have their Sunday meal, what time of

19    the day?

20       A.   Sunday meal, well, depends.  Depends on whether you're at home.

21       Q.   Let's say a family that is at home.

22       A.   It really depends.

23       Q.   Let's take a family that is home, would they typically have the

24    meal in the middle of the day or in the evening?

25       A.   Well, again, it depends.  Can be at 3.00, can be at 5.00,

Page 2588

 1    depends.

 2       Q.   Well, let me ask about your family.  What time would you typically

 3    prepare a Sunday meal for your children and your husband?  What time would

 4    you prepare the Sunday meal?

 5       A.   Well, depends if we are all there, then -- I can't really say

 6    exactly.  It depends when we are -- when we all get back home, when we're

 7    all there.

 8       Q.   Let's say that everybody is home, what time do you prepare your

 9    Sunday meal?  Nobody is working, nobody is going anywhere, just the family

10    is there, what time would you prepare the family meal?

11       A.   I don't know.  Depends on where we all get together.  I have no

12    idea.

13       Q.   Do you mind telling us who was Nikola's Godfather?

14       A.   Nikola's Godmother was Godmother kuma Smiljana Lukic.  She was the

15    one that christened him.

16       Q.   According to Serbian custom, does the child simply have a

17    Godmother or a Godfather or would a child have both a Godmother and a

18    Godfather?

19       A.   According to the Serb tradition, you start with your oldest kum

20    and then you go down the line that is the oldest son and then younger, but

21    Nikola had a Godmother because our kum Luka Lukic was in Austria and his

22    mother was there alone, so we invited her.

23       Q.   If Luka Lukic had been home, would your son have had a Godmother

24    and a Godfather or simply a Godfather, Luka?

25       A.   Well, in that case, it would have been only Luka Lukic because

Page 2589

 1    it's men come first and only if there are no men or if he is ill or

 2    something then somebody else.  You first start with men, and only then if

 3    no men are available, then you select a woman, then women's turn comes.

 4       Q.   Can you tell us what the relationship is between Smiljana Lukic

 5    and Milan Lukic?

 6       A.   I don't know.  They were Lukics.  What they were one to another, I

 7    have no idea.

 8       Q.   So you don't know whether your kuma is Milan's aunt or mother or

 9    some other relationship; you're not able to tell us that?

10       A.   Well, I'd say that she's his aunt, seeing that her surname is

11    Lukic so I guess she's his aunt or rather his father's brother's wife.

12       Q.   Can you tell us who is your daughter's Godfather?

13       A.   It was -- it is Luka Lukic.

14       Q.   I'd like to go back to the birthday party for a second.  You say

15    that Meho Dzafic had been invited in previous years to birthday parties

16    celebrated in your family; is that correct?

17       A.   Yes.  There were quite a number of Mitar's colleagues, Hodzic

18    Omer, a young one, Omer, an older one; Meho, I don't know, Sitni, I didn't

19    even know what his true name was.

20       Q.   And did Meho --

21       A.   Quite a number of them.

22       Q.   And did Meho accept these invitations and come to your house and

23    celebrate birthday celebrations in your house?

24       A.   Yes.

25       Q.   And can you give us an approximate number of how many times Meho

Page 2590

 1    was at your house at these birthday celebrations?

 2       A.   No.  Once, perhaps, for a birthday party, but otherwise, he came

 3    sometimes he just came to see Mitar.  At times he would give Mitar a ride

 4    back home and -- depends.

 5       Q.   Would you agree with me or would you say that he was at your house

 6    more than once or twice a month, that he would stop by your house?

 7       A.   I don't know how many times.  They all dropped by or came along

 8    with Mitar but I just don't know how many times.

 9       Q.   Now, can I correctly assume that Meho's family would have returned

10    the invitation and would have invited you and your husband to a birthday

11    or other celebrations in his family; would that be correct?

12       A.   I don't know.  They never invited -- Mitar usually invited his

13    colleagues and I usually invited mine.

14       Q.   What I asked you was:  Were you ever invited to a birthday party

15    that Meho was hosting for somebody in his family?

16       A.   Personally, I never went.  I don't know if Mitar did.  I know that

17    he was his colleague but I never went there.

18       Q.   Are you able to tell us the names of Meho's children?

19       A.   I -- no, I can't.

20       Q.   Are you able to tell us the name of Meho's wife?

21       A.   I don't know it.

22       Q.   Are you able to tell us the street that Meho lived on?

23       A.   I don't know.  Mitar knows it, perhaps, because they worked

24    together.  Perhaps Mitar knows his children and him, but I don't.

25       Q.   Can you tell us what car Meho drove?

Page 2591

 1       A.   Meho had a white, a small white Fiat, Fiat 600.

 2       Q.   Now, you told us yesterday a bit more about this kum relationship

 3    and you described for us very vividly the strength of this kum bond.  At

 4    one point you told us that if one breaks this kumship, then it is believed

 5    in Serbian tradition that bad things will befall the family that breaks

 6    this kumship; is that correct?

 7       A.   This is the old -- this was an old kumship, I don't know, 100 or

 8    200 years.  And according to our custom, there must be certain ceremonies

 9    if a kum needs to be changed, that you have to ask your former kum, but

10    it's not good to change your kum.  And as long as we live, Vasiljevic and

11    Lukic will always be kums.  They will never separate.

12       Q.   And am I correct in when I heard you yesterday when you said that

13    you believe that if that kum relationship were to be severed, that that

14    would bring bad luck or bad fortune upon the Vasiljevic family.  Is that

15    what you said yesterday?

16       A.   Well, according to some traditional beliefs, that is not even

17    permitted.  It is not permitted to sever this kind of relationship, and if

18    you do, yes, then ill luck will strike you.

19       Q.   So would I be correct in saying that in your mind, the Vasiljevic

20    family and the Lukic family are still in this kum relationship; correct?

21       A.   Why, of course.  We've never broken it.  But it need not mean

22    because we are living on and we have our offspring.

23       Q.   In your opinion, so let me ask for specifically, in your opinion,

24    is your husband still a kum of Milan Lukic?

25       A.   Why, of course.  Of course he is.

Page 2592

 1       Q.   And is he still a kum with Sredoje Lukic?

 2       A.   That's correct.

 3       Q.   Let me see if I have this correct, your husband has told us that

 4    Milan Lukic has done some terrible things and that according to him, your

 5    husband has been wrongfully accused of a crime he believes Milan Lukic

 6    committed, one of the most horrific crimes in the conflict.

 7            You have lost your husband for almost two years, you've lost the

 8    benefit of his wages for two years, your children have lost their father

 9    for two years, and it is still your belief that your family and the Lukic

10    family are kum?

11       A.   Well, we never broke our relations.  It doesn't mean that we shall

12    be with Milan Lukic, but our children and his children, these ties, these

13    bonds were never severed.

14       Q.   And one of the reasons they will never sever is because you

15    believe bad things will happen to your family if that relationship is

16    severed; correct?

17       A.   Well, according to our belief, that is not good.  It is not

18    advisable to change your kum.

19       Q.   Mrs. Vasiljevic, your husband is facing a charge for which he

20    could receive a very lengthy sentence.  Do you sincerely believe that this

21    kum relationship must persist despite all that has happened at this stage?

22       A.   Well, I don't know if it will go on.  I have no idea.

23       Q.   You told us yesterday that in the Uzice hospital, that a man from

24    Visegrad shared the room with your husband; is that correct?

25       A.   Yes.  There were several of them.  There were people who had been

Page 2593

 1    there before my husband.  There were a number of them there.

 2       Q.   I'm just interested in the people from Visegrad who were in the

 3    room at the same time as your husband.  How many people from Visegrad were

 4    in that same room?

 5       A.   I know there was a man whose first name was Dragan, and another

 6    one -- and he was from Visegrad, and there was a Muslim, I think.

 7       Q.   And that Muslim man was from Visegrad as well?

 8       A.   No.  No.  No.  I don't know.  I don't know where he came from.

 9       Q.   But Dragan was from Visegrad; correct?

10       A.   That's right.  Yes.  That Dragan was killed later on.

11       Q.   Can you tell us his last name?

12       A.   His last name was Filipovic.

13       Q.   And did you know why he was in the hospital at that time?

14       A.   Dragan, you mean?

15       Q.   Yes.

16       A.   I don't know.  He sustained some injury, whether his arm or

17    something.  I don't know.

18       Q.   And when did he die?

19       A.   Later on, after he was released from the hospital, later on I

20    heard that he was killed.  I don't know when.

21       Q.   Now, the day that your husband had this accident and broke his

22    leg, you told us that you were home the entire day; is that correct?

23       A.   Yes.  Yes.  I had a day off that day, because we usually set it at

24    the company level when would which shop be closed.

25       Q.   Well, you told us that this was the Feast of the Holy Trinity.

Page 2594

 1    Was your shop open that day and you just didn't work, or was the shop

 2    closed on that Sunday?

 3       A.   Well, you know, there is a schedule, so one shop is open on Monday

 4    and closes on Tuesday, and so on and so forth.  And that particular day, I

 5    was having a day off because our shop had a day off; that is, it was

 6    closed that day.  All the other shops were open and worked.

 7       Q.   What shop were you working in at that time?

 8       A.   In the supermarket, on the square.

 9       Q.   And even it being Holy Trinity Sunday, the other shops in Visegrad

10    town, you're saying, were open that day?

11       A.   Some were, some weren't.  It depended on the schedule, because

12    that's how we worked.  Some would be open on Sundays, others wouldn't.

13       Q.   Who would make up this schedule?  Who would decide which store

14    should be open on a particular day and which store should be closed?

15       A.   Well, in our company, the management.  I worked in a state-owned

16    company.

17       Q.   And so in 1992, your company was still owned by the state?

18       A.   Of course.

19       Q.   And you told us that you first learned that your husband had been

20    injured from your uncle, when your -- or I believe your husband's uncle

21    called on the phone; is that correct?

22       A.   No, no.  His uncle called me, his mother's brother, his uncle, not

23    his father's brother.  His mother's brother, that kind of uncle, on

24    his ...

25       Q.   And this is the man whose son was killed recently; is that

Page 2595

 1    correct?

 2       A.   Yes, yes, yes.

 3       Q.   And do you know where he was when he called you?

 4       A.   He was at home in Vardiste, and that's where he phoned me from,

 5    from his own house, because they stopped in the car that Mitar was in.

 6    There was a driver and somebody else, and he called me and said that Mitar

 7    had fallen off a horse and broken his leg.  They gave him a blanket to

 8    cover him up because he was cold, it was raining.  And of course, they

 9    took me off to Uzice.

10       Q.   Around what time did you receive that phone call?

11       A.   Well, I don't know what time it was exactly, but it was just

12    before dark, at dusk.

13       Q.   And before that -- well, that was the first way in which you

14    learnt; you heard nothing before that about your husband's accident.

15    Correct?

16       A.   Correct.  I didn't.

17       Q.   So it would seem, then, that all of the people, some of them

18    friends of your husband's, that came to his aid at the place where he fell

19    off the horse, none of those people called you to tell you that he had

20    been hurt; correct?

21       A.   Nobody.  Correct.  Nobody called me before that.

22       Q.   And we've heard testimony that he was in the Visegrad hospital for

23    a period of time, being x-rayed and being attended to.  During that period

24    of time, nobody from the hospital called you to tell you that your husband

25    was injured?

Page 2596

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Page 2597

 1       A.   They didn't.  Nobody called.  Probably they took him to hospital,

 2    and perhaps they didn't have enough petrol or cars.  You know, it was

 3    wartime.  So nobody called me except the uncle.

 4       Q.   Do you know -- or can you tell us where it was that your husband

 5    fell off the horse?

 6       A.   They told me later on.  It was in the square, Visegrad square,

 7    opposite the hotel, opposite the Visegrad hotel, in front of the garden

 8    and grill.  But there's the Panos terrace grill.  This was the other one,

 9    the UPI terrace grill, garden grill.

10       Q.   So was there a time -- and it's been almost nine years now - has

11    there been a time now that you have walked through that square with your

12    husband and perhaps your children, and your husband has said to you, "That

13    is where that old horse slipped and I fell"?

14       A.   Yes, I know where it is, more or less.

15       Q.   And did your husband point out the precise spot where the horse

16    slipped and fell?

17       A.   Well, we didn't actually go, but I know where it is, round about.

18            MR. GROOME:  Your Honour, I'm going to ask that the witness be

19    handed a blank piece of paper.  I've put "P107" on it.

20       Q.   I'm afraid we're going to ask you to draw something again.  I'm

21    going to ask you just to draw a representation of the square, whatever

22    shape it is.  We're not looking for scale or for accuracy.  Just draw a

23    representation of the square.

24       A.   Here, more or less.  This is the furniture store.  I don't know

25    exactly, but approximately.

Page 2598

 1       Q.   I'd ask you to draw a circle and put an "X" in it to indicate

 2    where it was that your husband told you he had the accident with the

 3    horse.

 4       A.   I don't really know.  [Marks]

 5       Q.   Did you put a circle with an "X" in it to mark that spot?  Before

 6    it goes onto the ELMO, can I ask you to draw a number "1" over the spot

 7    that you said was the furniture store.

 8       A.   [Marks]

 9       Q.   You've mentioned UPI coffee shop, I believe.  Can you put a number

10    "2" to show us where it is?

11            JUDGE HUNT:  It was the UPI terrace grill, actually.

12            MR. GROOME:  I'm sorry.  The UPI terrace grill.

13       Q.   And can you put the number "3" to show --

14       A.   Yes, yes, yes.  That's right.

15       Q.   Can you put the number "3" to show us where the Visegrad hotel

16    is.

17       A.   Visegrad [Marks].

18            MR. GROOME:  I'd ask that that be placed on the ELMO now.

19            THE WITNESS: [Interpretation] There's an Expres fast-food thing

20    and a department store.

21            MR. GROOME:

22       Q.   I'm going to ask you to put a "4" to indicate where this Expres

23    fast food is located and to put a "5" to show us where the department

24    store is located.

25       A.   [Marks] No.  That's where the fire brigade was.  You want the

Page 2599

 1    department store?  Well, that's the square, the fountain.

 2       Q.   Okay.  Before it goes back on the ELMO, just to be clear:  So

 3    you've put a "4" to indicate where the Expres fast-food shop is?

 4       A.   "4" is the Expres, next to the hotel.

 5       Q.   Okay.  And you've put a "5" to show us where the department store

 6    is?

 7       A.   And the snack bar is actually in the department store.  The

 8    department store is here, and the snack bar is within the department store

 9    somewhere.

10       Q.   And is there a number 5 to show us where the department store is?

11       A.   Yes, there is.

12            JUDGE HUNT:  One moment.  The snack bar is a new phrase, I'm

13    afraid.

14            MR. GROOME:  She's saying that's inside number 5.

15            JUDGE HUNT:  But which snack bar?

16            MR. GROOME:

17       Q.   Can you tell us which snack bar you're referring to?

18       A.   In the department store, up on the floor above.  In the department

19    store upstairs, there's a sort of cafe or snack bar.  Downstairs is the

20    department store, and the snack bar is upstairs, in the department store

21    upstairs.  The Expres is something separate, there's the Expres or fast

22    food, and there's the snack bar in the department store.

23       Q.   So you've told us about three places to eat.  The UPI grill, the

24    Expres food and the snack bar, those are three separate places?

25       A.   Yes, and the hotel, and the Visegrad hotel.

Page 2600

 1       Q.   Can we finish up, can you just write your name on the bottom of

 2    that piece of paper to indicate that it's you who's made that drawing.

 3    Just write your name on the bottom, the very bottom.  It's not over

 4    anything you've marked already.

 5            Perhaps it could be placed on the ELMO for us to see.

 6            Just so we're clear, the X that you marked to indicate where your

 7    husband indicated he fell from the horse, it's just to the left of the

 8    number 2?

 9       A.   Yes.  But perhaps I haven't drawn it accurately.

10            JUDGE HUNT:  Mr. Groome, there are two 5s now on the drawing.  I

11    don't know whether you keep a list of the instructions you give somebody

12    to do one of these complicated drawings, but the 5 as the snack bar is the

13    last name we used the number 5, but there's a 5 up there next to the "RX".

14            MR. GROOME:  Maybe that's the department store and the snack bar

15    is in side the department store and I'll just rely on the record for a

16    description.

17            JUDGE HUNT:  I'll leave it to you.  It's not clear to me, but I'll

18    leave it to you.

19            MR. GROOME:

20       Q.   Am I correct in saying that the number 5 indicates both the

21    location of the department store and the snack bar that's contained in the

22    department store; is that correct?

23       A.   The department store, and upstairs is the snack bar.  It's the

24    same building.  One is upstairs, the department store is downstairs.

25            MR. GROOME:  Thank you.  Your Honour, I would tender that now as

Page 2601

 1    Prosecution Exhibit P107.

 2            JUDGE HUNT:  Any objection, Mr. Domazet?

 3            MR. DOMAZET: [Interpretation] No, Your Honour.  I have no

 4    objections that the diagram be admitted, but Mr. Groome said that the

 5    witness, that Mitar had shown her the place.  She said that he had

 6    described the place, but never actually pointed it out to her on the

 7    spot.  So I'd like to clear that up.

 8            I have nothing against the diagram and sketch being admitted into

 9    evidence as being the place that she considers, according to his

10    description, that that was the place because I understood her to say that

11    he had described the place.

12       A.   No, I was never there.  I didn't actually see it for myself, but

13    he told me where it was.

14            JUDGE HUNT:  Madam, we'll get on a lot more quickly if you don't

15    talk over counsel, please.

16            What Mr. Domazet said is quite correct, but I don't think it

17    destroys the document as a document.  It will be Exhibit P107.

18            MR. GROOME:  I'm finished with that exhibit.

19       Q.   Mrs. Vasiljevic, I'd like to return now to the Sunday of the

20    accident.  What time did your husband leave the house that day?

21       A.   Well, Mitar left in the morning.

22       Q.   Are you able to tell us what time?

23       A.   I don't know.  I can't remember what time it was.

24       Q.   Was it before or after you got up from your bed?

25       A.   Well, not straight after he got up, of course.  I don't know

Page 2602

 1    exactly when.

 2       Q.   Well, had you arisen for the day and -- had the children had

 3    breakfast?  Can you tell us whether it was before or after the children

 4    had had their breakfast?

 5       A.   Well, I don't know.  I don't remember actually what -- when it

 6    was.

 7       Q.   Now, you've told us about your particular shop, the company that

 8    owned your particular shop, sometimes it would be open, and sometimes it

 9    would be closed depending on the schedule.  Your shop was a food shop;

10    correct?

11       A.   Yes, yes, food.

12       Q.   Now, in the town of Visegrad, there are many, many different types

13    of shops; correct?  Some would sell clothes, some would sell books; is

14    that correct?

15       A.   Not many shops, just five or six.  There are more food stores, but

16    otherwise, just one shop for each thing.  It's a small town.

17       Q.   And these other shops, can you give us an idea of the shops that

18    aren't food shops, what do they sell?

19       A.   Well, I don't know at that time which were open, which were

20    actually working at that time.  Some were on duty, open on Sundays, some

21    were open on Mondays, particularly for bread.  The bread stores were

22    open.  Supplies weren't that plentiful either so there weren't that many

23    goods in the shops.  There aren't many now either.

24       Q.   Would I be correct in saying that the stores that -- any stores

25    that would have been open on that Sunday would have been the shops like

Page 2603

 1    you describe, perhaps selling bread or milk or essential food that people

 2    would need on a Sunday; is that correct?

 3       A.   Well, bakeries were open selling bread, yes.

 4       Q.   Was your husband off from work that day?

 5       A.   My husband would go off for an hour or two to clean the town, and

 6    that's what he did that day too.

 7       Q.   So on this Holy Trinity Sunday, your husband did leave to clean

 8    the town; correct?

 9       A.   What's that got to do with it?  Had it been a saint day of ours,

10    our own personal family saint day, he might not have gone.  But otherwise,

11    everybody would work normally.  Those assigned would do so.  If it was our

12    family holy saint day or if we had been digging or constructing our house

13    he might not have gone, but as it's not our family holiday, wouldn't go.

14            Now, a family actually celebrating the Holy Trinity as their own

15    family saint day, then they would not go, but otherwise if it wasn't your

16    personal family saint, you could go to work.  We celebrate, for example,

17    St. George's Day so we wouldn't go to work on that day, whereas other

18    people who wouldn't have a family St. George's day would.

19       Q.   Your husband wasn't paid for this work, was he?

20       A.   No.

21       Q.   Did you make a dinner that day?  Did you cook dinner for your

22    family?

23       A.   Normally, of course.

24       Q.   And what time did you plan to serve the dinner that day?

25       A.   Well, I don't really know because of what happened to Mitar, so I

Page 2604

 1    don't actually know.

 2       Q.   So you've forgotten because of the accident?

 3       A.   We probably had dinner sort of a late meal.

 4       Q.   Would he have been there for that meal?

 5       A.   Yes, probably he would have because it was a late meal, a little

 6    later than we would usually eat.

 7       Q.   And can you give us an idea of when you say "late meal," around

 8    what time of the day would you consider it to be a late meal?

 9       A.   Well, late is 8.00, but this might have been before, a little

10    before 8.00 when I heard the news.  I think it was 7.00 or 8.00.  After

11    that, it would be too late for dinner.

12       Q.   And Mitar was present when your family ate that day; is that what

13    you're telling us?

14       A.   No.  No.  No, he wasn't.

15       Q.   From the time he left in the morning, did you see him again that

16    day?

17       A.   Well, I don't know.  He would go in and out several times.  Now,

18    what happened that day, I can't say.

19       Q.   So it is possible that he returned home after finishing his

20    cleaning and then went out again; is that what you're telling us?

21       A.   I can't remember because sometimes during a day, he would go out

22    and work for an hour or two and come back home and then leave again.  I

23    can't remember.

24       Q.   And where would he go when he would leave again?

25       A.   Well, he'd come home, have a bit of a rest sometimes.  Sometimes

Page 2605

 1    he'd have some odd job to see to.

 2       Q.   Were you expecting your husband home for the meal that day?

 3       A.   Of course.

 4       Q.   When did you first know who Milan Lukic was?

 5       A.   Well, I knew that Milan Lukic existed, but I had never seen him

 6    before the war broke out and before I heard that he had come to Visegrad.

 7    I think as soon as the Uzice Corps came, then, I am not quite sure.  He

 8    suddenly turned up in Visegrad around that time, I think.

 9       Q.   When you married your husband, how old would you say Milan Lukic

10    was at the time?

11       A.   I don't know.  I didn't know him then at all, nor was he around.

12    I don't know.

13       Q.   Let me go back to this kum relationship again.  At the time that

14    you were married, your family or Mitar's family and the Lukics were in

15    this kum relationship.  My question is:  Would it not be natural to assume

16    that Milan Lukic probably, whatever age he was, perhaps a teenager at the

17    time, was at your wedding?

18       A.   No, no.  He's much younger than us, at least 15 years, about 15

19    years younger than us.

20       Q.   Are there any family celebrations over the years prior to the

21    Uzice Corps arriving in Visegrad that you can recall seeing Milan Lukic at

22    one of the family celebrations?

23       A.   No, no.

24       Q.   And how about Sredoje Lukic?

25       A.   Sredoje was in Visegrad.  That's where he lived.

Page 2606

 1       Q.   And would you see him at different family celebrations?

 2       A.   Perhaps for our Slava, family holy day.

 3       Q.   Did he attend your wedding?

 4       A.   No.

 5       Q.   Now, just another point on Serb traditions, isn't it correct that

 6    there are actually two parts to a Serbian wedding?  The first part in the

 7    registrar office, the government office, and then the second part in the

 8    orthodox church presided over by the priest; isn't that correct?

 9       A.   That's true, but we didn't have a big wedding.  We just had the

10    ceremony at the registry.  We never got married in church.  It's not

11    obligatory.  You don't have to.  You don't have to get married in church

12    after the civil ceremony.

13       Q.   To your knowledge, did Milan Lukic ever have the second part of

14    his wedding ceremony, the part of the ceremony in the church?  Are you

15    aware of him ever having that?

16       A.   No.  No.  I don't think -- I don't believe he married in church.

17    I don't think he had a church ceremony as well.

18       Q.   Prior to Milan Lukic's wedding, did your husband ever express

19    reservations about being his best man?

20       A.   No.  Milan didn't even have a wedding.  He got married, and Mitar

21    was the witness at the registry, just for an hour or two.  That's what he

22    told me, that it was all very quick.  They just went to the registry

23    office to get married.  It all lasted a short time.  He didn't make an

24    actual wedding, big wedding.

25       Q.   And after the wedding, or the day of the wedding, did he come and

Page 2607

 1    tell you what happened that day, that Milan Lukic had been married that

 2    day?  Did he tell you that?

 3       A.   No, but as he was talking, he said that Milan asked him in

 4    passing.  As a rule, he should have invited his father, but his father

 5    lived a long way away.  There was no transport.  I think Mitar's father

 6    was ill.  And then he got to know Mitar, who is the eldest son of the

 7    father.  And it just took one or two hours in the registry office.

 8    Whether they went to have lunch or not after that, I don't know, but it

 9    was all very brief.

10       Q.   Have you ever seen photographs from Milan Lukic's wedding?

11       A.   No.  There weren't any.  There was no photographing.

12       Q.   Did your husband ever express reservations or concerns that he had

13    after the wedding, telling you something to the effect that he didn't want

14    to be his best man but he felt he was obliged to?  Did he ever say

15    something in substance like that?

16       A.   Well, he didn't feel the same way as he had earlier on, but that's

17    how it had to be, following on from the tradition.

18       Q.   Well, can you tell us what he said to you after he was the best

19    man at Milan's wedding?

20       A.   Well, he didn't say anything special.  He just said he met him and

21    that he asked him to do this.  He couldn't refuse, of course, because he

22    couldn't call anybody else.  His brother was in Belgrade, and the others

23    were I don't know where, so he couldn't refuse him.

24       Q.   Now, the baptism of Milan's child, who from your family attended

25    that?

Page 2608

 1       A.   My Mitar and Marina and Nikola.

 2       Q.   And why was it that you did not attend?

 3       A.   Well, I don't know.  Probably I had to go to work or something

 4    like that, because I was the only breadwinner.  Nobody else was working at

 5    that time, so I had to go to work.

 6       Q.   So is it true your husband never returned to work at the Panos

 7    restaurant after the conflict?

 8       A.   I think he started working in one of Panos's smaller catering

 9    establishments, a smaller restaurant that they owned.

10            MR. GROOME:  It's 11.00.

11            JUDGE HUNT:  We'll resume at 11.30.

12                          --- Recess taken at 11.00 a.m.

13                          --- Upon resuming at 11.28 a.m.

14            JUDGE HUNT:  Mr. Groome.

15            MR. GROOME:

16       Q.   Mrs. Vasiljevic, just before the break, we were talking about your

17    husband working at Panos.  My question to you is after he was -- after he

18    got out of the hospital, did he return to work in the Panos -- or work for

19    the Panos company?

20       A.   Yes.  He returned to Panos in -- could have been late 1992, end of

21    1992.

22       Q.   Did he work for the Panos company up until the time of his arrest?

23       A.   No, he did not.

24       Q.   When did he stop working for the Panos company?

25       A.   I wouldn't know.  He quit because they were not paying any

Page 2609

 1    salaries or anything, so he worked for a while, for a rather short while,

 2    and then he simply quit because -- and they were not paying out any

 3    salaries or anything.

 4       Q.   Did you know a person by the name of Behija Zukic?

 5       A.   What did you say her name was?  I didn't get it.

 6       Q.   In case my pronunciation isn't 100 per cent correct, the person

 7    I'm asking about is a person whose name is Behija Zukic who owned a shop

 8    with her husband.  Do you know the person who I'm referring to?  I believe

 9    your husband told us that the shop was on the way home from Visegrad to

10    your house.

11       A.   Yes.  Yes.  I did know her from about the shop.  She had her own

12    shop.

13       Q.   Would you ever go to that shop to buy groceries?

14       A.   Of course.  Yes.

15       Q.   Now, a number of witnesses have told us about a car that she had,

16    a red Passat, that it seemed that many if most of the people in Visegrad

17    recognised as being owned by her.  Are you familiar with this red Passat?

18       A.   I don't.  I don't know who had what car.  I have no idea.

19       Q.   So you do not know what car Behija Zukic had, do you?

20       A.   I don't.  No, no.  I didn't know it.  I knew her but I didn't know

21    anybody else, not her husband, nor her children.  Nobody.

22       Q.   I want to ask you a few questions now regarding your husband's

23    alcoholism.  When would you say he first had a problem with drinking?

24       A.   Well, he always drank, and he would always be in trouble when he

25    drank for longer periods of time, and of course he eats nothing when he

Page 2610

 1    drinks and then, of course, we have to go to the doctor.  Even before, I

 2    believe he was treated for alcoholism sometime in the 1980s, I believe.

 3       Q.   Did he have this problem before you were married?

 4       A.   Well, I wouldn't really know how about before, but he had this

 5    problem ever since we were married.  You know, he doesn't drink and then

 6    he goes on a drinking bout and drinks for five or six days, and then he

 7    eats nothing and of course he loses weight so he has to go to the doctor

 8    to get an infusion to recover, start eating again.

 9       Q.   Was there anything that you were able to do when he was in one of

10    these drinking bouts?  Was there anything that you were able to do to help

11    him get out of it?

12       A.   Why of course, but he could not even take any food in.  So he did

13    need this infusion to recover a little because when he consumed alcohol,

14    he simply did not eat anything.

15       Q.   Would I be correct in thinking that when he was on one of these

16    drinking bouts, that he would spend some of his wages on alcohol?

17       A.   Well, he was very sociable so he liked company, he'd stay with

18    them and he'd spend the money, but then he would make up for it by

19    working, and that is what he did.  He would work more until he made up for

20    that.

21       Q.   Was his drinking, did it ever create a financial hardship for you

22    and your children?

23       A.   Well, it's not that we were indifferent to it, but he always tried

24    to make up for all that to somehow make amends for what he's lost, for

25    what he's spent.

Page 2611

 1       Q.   How often would he go on these drinking binges?

 2       A.   Well, he did drink for a while, and then he wouldn't drink

 3    anything for some months and then he would start drinking again and that

 4    was it.

 5       Q.   How many times a year would he have these drinking bouts?

 6       A.   Well, depends.  Sometimes five or six months would go by without

 7    any alcohol, sometimes those intervals were shorter.  It depends.

 8       Q.   At the times when he was drinking a lot, was it possible for you

 9    to reason with him?  Could you discuss a matter with him about the

10    children or perhaps about the house?  Was it possible to discuss something

11    with him?

12       A.   Why, yes, of course.  In the beginning, it wasn't easy at all, I

13    mean when he drank excessively, but then he'd stop drinking and everything

14    would be back to normal.  He wasn't aggressive or anything.  Yes, we could

15    talk.

16       Q.   Did you ever have a disagreement with him while he was drunk?

17       A.   No.

18       Q.   Did he ever shout at your children while he was drunk?

19       A.   No, no, he doted on his children.  No, never.

20       Q.   From what you're telling us now, it seems that the only real

21    problem with your husband's drinking is that he stopped eating and would

22    lose weight.  Other than that, it doesn't seem that it had much impact on

23    the family; is that correct?

24       A.   Quite, quite.  Nothing else.  It was only bad for him, because his

25    health would deteriorate and at times he would ramble, so that he would

Page 2612

 1    have to go to see a doctor.

 2       Q.   So your primary concern was not so much for anything he might do;

 3    it was simply for his own physical health.  Is that correct?

 4       A.   Of course, because it was bad for him.  He was running himself

 5    into trouble.

 6       Q.   I want to draw your attention to May and June of 1992.  Did there

 7    come a time when everything you've described now changed, that now your

 8    husband's behaviour seemed somewhat different to you?

 9       A.   Well, there would be a change, like sometimes when he could not

10    bear something; for instance, when he was in the hospital and saw those

11    wounded men without arms, without legs, and then he would be quite

12    distraught.  I mean, he could not bear that, and I could see it in his

13    behaviour that he really was very unhappy when he saw things like that.

14       Q.   I'd actually ask you to focus on the time period before he went

15    into the hospital.  Did there come a time when you noticed, let's say

16    somewhere at the beginning of June, a dramatic change in his behaviour

17    that concerned you very much?

18       A.   Why, yes.  He started drinking more when his cousin Zeljko was

19    killed.  He changed then.  He was very cut up, because that cousin was his

20    father's single son, so that he mourned him truly, he cried a lot, could

21    not come down.

22       Q.   And did that change in behaviour remain up until the time that he

23    went into the hospital?

24       A.   Well, he was always quite upset when something like that

25    happened.  He would be less coherent when he was distressed by something.

Page 2613

 1       Q.   When you say "less coherent," do you mean it was more difficult to

 2    have a discussion with him about something that you needed to discuss?

 3       A.   Well, not that it was more difficult, but he would -- he could not

 4    properly focus when he would be cut up by one of such things.  Then he'd

 5    really feel it.

 6       Q.   Would you call him -- would you consider him as having been

 7    depressed after the death of his cousin?

 8       A.   Well, yes.  Yes, he was depressed.  He cried for days on end.  He

 9    somehow could not accept that situation.

10       Q.   Would you consider that he became more aggressive after his cousin

11    died?

12       A.   No.

13       Q.   Did you consider him perhaps excitable or agitated at the time

14    after his cousin died?

15       A.   Why, no.  Perhaps slightly more nervous.

16       Q.   After his cousin died, did you notice that perhaps he was staying

17    out for long periods of time and not returning home?  Did that happen?

18       A.   Not really.  He liked to go, to leave, and then come back.  There

19    was only once that for about two or three days I didn't know where he was,

20    so I asked around, and I was told that he was at Uzamnica and that he was

21    on a hunger strike.  It was then that he did not come back and that I was

22    told that he had been detained there, that he had been disarmed, that he

23    wasn't eating, so that a doctor or a nurse, or whoever it was, went up

24    there to administer a drip.

25       Q.   So between the time that his cousin died and the time that he went

Page 2614

 1    into hospital, other than this period of two or three days, he would come

 2    home every night and there was nothing that concerned you about his

 3    behaviour; is that correct?

 4       A.   Well, then, when his cousin was killed, it could have been a day

 5    later that he returned home, quite disturbed.  He was very shaken when he

 6    mentioned his colleague, but he was really -- he was really making no

 7    sense, so that I couldn't really understand what he was trying to tell me.

 8       Q.   Let's put aside for a second what he may have told you.  From the

 9    time that he's released from Uzamnica up until the time that he goes into

10    the hospital - and according to him, that seems to be about two weeks,

11    from the 1st or the 2nd to the 14th - during that two-week period, was he

12    coming home at night?

13       A.   Yes.  Yes.  He continued to clean the town then, going away for an

14    hour or two.  They would clean the town, and after that he would come back

15    home.

16       Q.   And was there anything during that two-week period about his

17    behaviour that caused you concern, that made you worry, anything at all?

18       A.   No.

19       Q.   Mrs. Vasiljevic, I want to read you a portion of your husband's

20    medical record, and then after I read it, I'm going to ask you a few

21    specific questions.

22            "Wife's description of case history:  'He used to drink a lot of

23    alcohol but was never aggressive.  Since the beginning of the fighting, he

24    has always been engaged, agitated, impatient.  He is always going

25    somewhere and remains in the unit, even when his shift is over.  He was

Page 2615

 1    particularly upset by the death of a close relative.'"

 2            Now, the question I have for you is:  Did you tell a doctor who

 3    was treating your husband in Uzamnica hospital that your husband seemed

 4    engaged?

 5       A.   What do you mean by "engaged"?

 6       Q.   That's the word that the doctor wrote in the statement.  Do you

 7    remember using any word of that nature when discussing your husband's

 8    condition with the doctor?

 9       A.   I don't know.  I know that he was treated by orthopaedic

10    surgeons.  I suppose he could not simply watch those people who were

11    around him, because they were people from Bajna Basta, from Zvornik, from

12    Visegrad, the wounded, and I suppose he simply couldn't bear to look at

13    them any more, so they moved him from the orthopaedic ward to the other

14    ward, I suppose.  Something must have disturbed him there, shaken him.

15       Q.   Would you agree with me that the portion of the medical record

16    that I just read to you doesn't indicate that you said your husband was

17    incoherent or not making sense, but that it says that you told the doctor

18    that he was engaged, agitated, impatient?  You'd agree with me that

19    there's nothing about being incoherent in that portion that I read?

20       A.   No, no, no.  No, no, no.  No, no, no.  No.  He must have been

21    affected, disturbed by certain things that happened there, I mean where he

22    was -- the room he was in.  I can't remember the words that I used then.

23       Q.   Did you tell the doctor that he was agitated?

24       A.   I don't know what I said to the doctor.  I only could see that he

25    was in a poor shape, that they were giving him sleeping pills, that he

Page 2616

 1    looked very exhausted, and that is when I asked that he be released home,

 2    because at that time there was a shortage of medicines, even at the

 3    hospital.  So at home I had to look for those medicines.  Then there was a

 4    shortage of food, because there were wounded from all over the place, and

 5    that was why I asked to take him home.

 6       Q.   Did you ever tell the doctor that your husband was impatient?

 7       A.   No.

 8       Q.   Now, it says also that you stated, "He is always going somewhere."

 9    What did you mean by that, "He is always going somewhere"?

10       A.   Now, when did I say that?  When, to whom did I say that?

11       Q.   This is a note from a doctor contained in your husband's case

12    history.  I don't have the exact date in front of me, but my best memory

13    is that it's around July of 1992 is the time when the doctor made this

14    note.  Did you ever tell a doctor treating your husband, "He is always

15    going somewhere"?

16       A.   No, no, no.  I think it was the doctor who said that because it

17    was the doctor who wrote his case history.  I don't remember saying that.

18            THE INTERPRETER:  Could the original please be placed on the ELMO

19    for interpreter's sake?

20            MR. GROOME:  I'm going to ask that the witness be shown

21    Prosecution Exhibit 138.

22            JUDGE HUNT:  It's not the witness who has to see it, it's the

23    interpreters.

24            MR. GROOME:  We're asking that it be put on the ELMO.

25            JUDGE HUNT:  Well, that means it goes on the ELMO.

Page 2617

 1            MR. GROOME:  Yes, Your Honour.

 2            THE INTERPRETER:  Thank you, Your Honour.

 3            MR. GROOME:  I would just ask the interpreters is it the portion

 4    that they need to see visible on the ELMO at this stage?

 5            JUDGE HUNT:  The bit that you are reading, that's what they need

 6    it for.  That's why they usually are given copies of this when you are

 7    cross-examining on them.

 8            MR. GROOME:  I apologise for not having done that, Your Honour,

 9    but as I do not speak B/C/S I'm unable to know if the portion -- but the

10    entire page is not visible on the ELMO.

11            THE INTERPRETER:  No, no.  That was not the fragment that was read

12    by the Prosecution.

13            MR. GROOME:  May we simply give this exhibit to the interpreters

14    so that they may find the portion.

15            JUDGE HUNT:  It will be much easier for them, certainly, except

16    that they'd have to share it then.  There is more than one interpretation

17    going on.

18            MR. GROOME:  The case manager is making a copy.  Maybe we'll go on

19    to the final area and then come back to this.

20            JUDGE HUNT:  I think that's a good idea.

21            MR. GROOME:

22       Q.   Mrs. Vasiljevic, copies are being made of the original document to

23    be sure that we're using the precise words that the doctor wrote down.  I

24    want to ask you about two events.  I want to draw your attention to around

25    the 18th of May, and I'm going to be asked that you be shown the pseudonym

Page 2618

 1    sheet, P106.

 2            I'm going to draw your attention to VG81.  Is it your testimony

 3    that at no time in May or around that period of time that that witness was

 4    not stopped in front of your house by your husband, in your presence, and

 5    a conversation took place between you?  Is that your testimony?

 6       A.   Which year, May, May, which year, 1992 or ...

 7       Q.   Yes, in 1992.

 8       A.   I never saw that person, nor did I ever come out.  I know the

 9    person, but I did not come out, nor was I having any argument with that

10    person at the time.

11       Q.   I draw your attention to another name on that list, VG13.  Do you

12    see that person's name?

13       A.   I do.

14       Q.   And you know that person as well, don't you?

15       A.   No.  I don't know that person at all.  Maybe I might but, no, I

16    don't, I don't know this name.  I wouldn't know that person by name.

17       Q.   When you say you might, do you think you know that person or

18    you're pretty sure that you do not know that person?

19       A.   Well, now when I look at it, I just do not know that person.

20       Q.   VG13 states that sometime last year, you called her up and you

21    asked her or, I'm sorry, you offered her money if she would not testify

22    against your husband in this trial, and she also stated that you told her

23    that you had spoken to VG18 on that list and had convinced her not to

24    testify.  Did that phone conversation take place?

25            JUDGE HUNT:  Yes, Mr. Domazet.

Page 2619

 1       A.   No.

 2            MR. DOMAZET: [Interpretation] Your Honour, from what Mr. Groome

 3    has just said, one could interpret it as if the witness VG13 said that

 4    here in the courtroom, and I truly cannot remember it ever being mentioned

 5    during the trial or during the testimony of that particular witness.

 6            JUDGE HUNT:  I agree with you that there was no reference in that

 7    witness' evidence, but I don't think that the question or the sense of the

 8    question depends upon where VG13 said it.

 9            It is always better, if I may say so, Mr. Groome, that these sorts

10    of allegations are put directly rather than trying to attribute them to

11    somebody.  It causes confusion, and it isn't really the point you're

12    trying to make.

13            You are accusing her of doing this.  It's got nothing to do with

14    VG13.  Anyway, she has denied it.

15            MR. GROOME:

16       Q.   Mrs. Vasiljevic, did you ever contact VG18 and say anything to

17    that witness, and that witness' name is on the list before you?

18       A.   I have no idea where that person is.  I wouldn't know which --

19    where to call that person, which town, which city to call to find that

20    person.

21       Q.   I want to go back to the medical record.  The interpreters now

22    have a copy so we can use the precise language that the doctor wrote.  And

23    I'll go back to the first description of "engaged," and I'll trust that

24    they'll give you the exact word that is written in the record.  Did you

25    ever say to the doctor that your husband was engaged?

Page 2620

 1       A.   What do you mean by "engaged"?

 2       Q.   I presume that the interpreters have just used the precise word

 3    that the doctor noted.  Did you ever use that word when describing your

 4    husband?

 5       A.   I don't know if I was asked to describe it or was it up to that

 6    doctor to describe the state of his health.  I presume that the case

 7    history must have been written by the doctor, not by myself.

 8            JUDGE HUNT:  Mr. Groome, may I suggest that you will get a lot

 9    further that you cease to attribute to this witness the word "engaged."

10    It's a very medical term.  What you have to put to her is did she ever

11    suggest anything which suggests that he was able to reason or to converse,

12    whatever meaning you seek to attribute to the word "engaged."

13            It doesn't purport to be a verbatim statement by this witness.

14    It's a medical history and doctors, unfortunately, use words quite

15    differently to people.

16            MR. GROOME:  That's why I'm simply asking her did she use the

17    word.

18            JUDGE HUNT:  You have now.  But up to this stage, you have kept on

19    ascribing to her the use of the word "engaged."  Now, if you want to get

20    somewhere, may I suggest you put your meaning on it and ask her whether

21    she said anything -- I don't know, I haven't looked it up in the medical

22    dictionary, but if you have a particular meaning to the word "engaged,"

23    that you seek to have attributed to the witness, ask her if she said

24    anything along the words of whatever that meaning is.

25            MR. GROOME:  I have no particular meaning to the word other than

Page 2621

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 9  

10  

11  

12   Blank page inserted to ensure pagination corresponds between the French and

13   English transcripts.

14  

15  

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17  

18  

19  

20  

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Page 2622

 1    to rely on the official translation of the word she used.

 2            JUDGE HUNT:  She didn't use it.  Now, there's no suggestion that

 3    she used it.  She's denied it.  There's nothing on the document to suggest

 4    she's used it.  It's a medical history.  A medical history is something

 5    that puts down in the doctor's understanding of terms.

 6            Now, if you want to get somewhere, I'm trying to assist you to get

 7    somewhere on this, use what you suggest is the meaning.  If you have no

 8    meaning and she's denied the use of the word, we're not going to get

 9    anywhere by continually asking her the same question.

10            MR. GROOME:

11       Q.   Let me ask you about the word "impatient," and I'd ask you to use

12    the ordinary sense of that word, not a medical term.  Did you ever

13    describe your husband in the ordinary sense of the word as impatient?

14       A.   Well, yes, he was impatient.  I don't know how to put it.

15       Q.   Did you ever describe your husband --

16       A.   How do you mean?  Where was he impatient, in hospital?  Was

17    impatient in hospital, do you mean?  It depends whether he was waiting for

18    something to happen and then was impatient or -- because if he was ill and

19    impatient in hospital, that's something else.

20       Q.   Did you ever describe your husband as being impatient in the

21    period before his hospitalisation?  Did you ever describe him as being

22    that way to a doctor?

23       A.   Nobody asked me.  I don't know.

24       Q.   Did you ever describe your husband to a doctor using the ordinary

25    sense of the word "agitated"?  Did you ever describe your husband as being

Page 2623

 1    that prior to his hospitalisation?

 2       A.   Well, I don't know whether I said anything like that.  I really

 3    don't know.

 4       Q.   Did you ever tell a doctor that your husband was always going

 5    somewhere prior to his hospitalisation:  "He is always going somewhere"?

 6    Did you ever say that to a doctor?

 7       A.   Well, I don't know if I told a doctor that.  I don't know whether

 8    it had anything to do with it.

 9       Q.   You've testified just a few minutes ago that in the time period

10    between your husband's cousin dying and the time that he went into the

11    hospital, that he came home every night except the two or three days he

12    was in Uzamnica; correct?

13       A.   Yes, that's right.  I didn't know where he was for two or three

14    days, until they told me.  They told me that he was in detention in

15    Uzamnica and was refusing food.

16       Q.   So is the doctor mistaken when he has a note saying "wife's

17    description," and it says:  "He is always going somewhere"?  Is that an

18    inaccurate statement?

19       A.   I don't know what he wrote down.  I don't know what I actually

20    said to the doctor.

21       Q.   Okay.  I don't know what you actually said.  I can only tell you

22    what is actually written down, and what's written down is:  "He is always

23    going somewhere."  Did you ever say that to the doctor?

24       A.   I don't know.  I don't remember.  I don't remember what I said, I

25    really don't.

Page 2624

 1       Q.   Did you ever say to the doctor:  "He remains in the unit even when

 2    his shift is over"?  Did you ever tell a doctor that your husband remained

 3    in a unit even when his shift was over?

 4       A.   I don't remember that either.

 5       Q.   You never referred to his cleaning crew as a unit, did you?

 6       A.   No, never.  I don't know who worked with him.

 7       Q.   Well, at this period of time, this two-week period, he was not

 8    working other than the cleaning crew; correct?

 9       A.   Yes.  He just cleaned the town, that kind of thing.

10       Q.   Mrs. Vasiljevic, isn't it a fact that you did say to the doctor:

11    "He remains in the unit even when his shift is over," and that the unit

12    you were referring to is Milan Lukic's unit, a unit of the White Eagles?

13    Isn't that the truth of what you said to a doctor?

14       A.   No.  No.  Mitar was never with them, nor did I ever say that.

15            MR. GROOME:  I have no further questions.

16            JUDGE HUNT:  Re-examination, Mr. Domazet?

17            MR. DOMAZET:  Yes, Your Honour.

18                          Re-examined by Mr. Domazet:

19       Q.   [Interpretation] Mrs. Vasiljevic, from Mr. Groome's question,

20    there were some slight problems, perhaps because of the different

21    terminology used in the English language or perhaps for some other

22    reason.  Could you explain to us, when you said that Mitar never wore a

23    mantle or topcoat, when you said that, could you explain to us which coat

24    you had in mind, what you mean when you say "mantle" coat, light coat?

25       A.   Where I come from, a coat is if you put -- if you -- say you have

Page 2625

 1    a suit on and a shirt and a tie, then when you get dressed up like that,

 2    you would put a coat over it, that type of coat that we call mantil.  I

 3    don't know if you understand me.  And he never had one of those.

 4       Q.   Could you explain to us briefly the difference between what we

 5    call a kaput, or great coat, and mantil, a lighter form of coat, as both

 6    these items of clothing are long.  But there is a difference in our

 7    conception of them, is there not?  And I think that we shall explain to

 8    the Court what we mean if we describe this.

 9       A.   A kaput is a kaput.  A mantil is lighter in weight, perhaps

10    longer.  I don't know how to explain the difference.  One that you put on

11    over a suit when you get dressed up that way.  Mitar never owned one.  He

12    had the jackets, men's jackets that you wear in winter, and that kind of

13    thing, and a lighter jacket when the weather wasn't so cold.

14            JUDGE HUNT:  I think, Mr. Domazet, you may find yourself in the

15    witness box very shortly.  Are we talking about something such as a

16    difference between an overcoat and a skiing jacket?  I'm trying to get the

17    sense of the way you described it, you see, without having to put you in

18    the witness box to give it to us.

19            MR. DOMAZET: [Interpretation] A skiing jacket is something that is

20    thicker, yes, but it is short in length, the length of a jacket to a suit,

21    whereas the kaput and the mantil are longer, like what I'm wearing,

22    perhaps a little shorter, but there is a difference.  The witness said

23    thinner, lighter, and I think that's --

24       Q.   Madam Vasiljevic, when you say "thinner" or "lighter," which of

25    the two things, if you have a kaput and a mantil, which is thinner and

Page 2626

 1    lighter?  Which is made from a thinner and lighter --

 2       A.   Well, the kaput is much thicker, longer, worn in winter, whereas

 3    the mantil type is thinner, lighter in weight, and you wear it over a

 4    suit.  And Mitar never had one of those.

 5       Q.   Thank you.  I think we have tried to clarify that point

 6    sufficiently and to get an answer.  Thank you.

 7            Asked another question by Mr. Groome about your kums and the kums

 8    to your children, you said that one child was christened by Smiljana Lukic

 9    because Luka Lukic, the wedding kum, was not able to come, whereas the

10    second child was christened by Luka Lukic.  I should like to try to ask

11    you to remember exactly which child was christened by Smiljana Lukic and

12    which child was christened by Luka Lukic?  Which of your two children had

13    which kums?

14       A.   I don't know what I said exactly, but Marina was christened by kum

15    Smiljana and Nikola was christened by kum Luka.

16       Q.   Thank you.  Mrs. Vasiljevic, asked by Mr. Groome about who came to

17    your son's birthday parties or which colleagues Mitar would bring home

18    from time to time, you enumerated several colleagues, you gave several

19    names, and from that I gather that those several people were Muslims,

20    judging by their names - I say that, "judging by their names" - and that

21    among them you mentioned Meho Dzafic; is that right?

22       A.   I think there were ten or so colleagues, about ten colleagues.  I

23    don't know exactly whether Meho was among them, but I think he was.  I

24    know that Hodzic, Agic, a man named Omer, they came.  I forget the

25    others.  I know there was a number of them.

Page 2627

 1       Q.   When you say, Mrs. Vasiljevic, that there were a number of them,

 2    and you go on to enumerate Hodzic, Agic, Omer, and so on - just a moment,

 3    please.  Let me finish, please, Madam - were they your husband's

 4    colleagues who were Muslims, of Muslim ethnicity?  Is that right?  Could

 5    you give me a yes or no answer, please.  That will facilitate matters.

 6       A.   Yes.  They were Muslim -- of Muslim ethnicity.  There were others,

 7    too, but I can't remember the names now.

 8       Q.   What about the three men you mentioned, as well as Meho Dzafic,

 9    who you spoke about?  Were they colleagues of your husband who would come

10    by to your house with him from time to time, whom he would bring home from

11    time to time?

12       A.   Yes.  They were all Mitar's colleagues who came by from time to

13    time.  There were others too.

14       Q.   Mr. Groome also asked you whether you knew their wives, or rather,

15    the wife of Meho Dzafic, whether you knew Meho Dzafic's wife.  Now, let me

16    ask you:  On those occasions when your husband brought his colleagues

17    home, did he bring their wives home as well or did they come only on their

18    own, themselves, just the husbands?

19       A.   Only the husbands.  Their wives did not come.

20       Q.   Thank you.  In mentioning the Uzice hospital and your going, can

21    you remember how many times you went to the hospital while your husband

22    was lying in Uzice hospital?  And I'm thinking about 1992 when I say

23    that.  Do you happen to remember how many times you went?

24       A.   Yes.  Twice, I think, to the orthopaedics ward, and once when they

25    put him into the ordinary daily ward.

Page 2628

 1            THE INTERPRETER:  I'm sorry, could the witness repeat the latter

 2    half of her answer?  "Once ..."

 3            MR. DOMAZET: [Interpretation]

 4       Q.   So twice to the orthopaedics and once to the neurological

 5    department.  Was this a visit to the neurological department, and the

 6    fourth time when you took him out of the hospital?

 7       A.   Yes.

 8       Q.   So that means three visits and once when you came to take him

 9    home; is that right?

10       A.   Yes.

11            JUDGE HUNT:  Mr. Domazet, the interpreters missed the reference,

12    if it was to the neurological department.  They stated at the time the

13    witness was answering it that they could not hear the end of her answer.

14    You heard it as neurological department, did you?

15            MR. DOMAZET:  Yes, Your Honour.

16            JUDGE HUNT:  Thank you.

17            MR. DOMAZET: [Interpretation]

18       Q.   Mrs. Vasiljevic, for the interpreters and the transcript, please,

19    would you repeat.  Apart from the two visits to the orthopaedics ward,

20    your next visit was to what ward?

21       A.   I don't know whether I'll use the right term medically,

22    neuropsychiatry or neurology.  Neuropsychiatry, I think it was, to the

23    neuropsychiatric ward.

24       Q.   Yes, but it was the ward he was in after he left the orthopaedics

25    ward; is that right?

Page 2629

 1       A.   Yes, yes, that's right.

 2       Q.   Asked by Mr. Groome, Mrs. Vasiljevic, about the stores and shops

 3    which were open on Sundays, I think you explained that some stores were

 4    open, others were not, and on that particular Sunday that you were asked

 5    about, was the Holy Trinity holiday.  Now, I want to ask you this:  Were

 6    shops open generally on religious holidays such as the one in question,

 7    and are there any religious holidays when shops were shut because it was a

 8    religious holiday?

 9       A.   Well, of course the management decided when shops would be open

10    and when not.  The Holy Trinity holiday is one that lasts three days.  So

11    I don't know who determined this, but I know that they decide which shop

12    is going to be open on the first day of the holiday, and that would be the

13    shop selling food, food stores and bakeries.  Then for the second day of

14    holidays, somebody else would be on duty, other shops would be open, and

15    the same applied to the third day of the holiday depending on what the

16    management, what schedule the management had made up.

17       Q.   Thank you.  Yes.  But let us go back and speak about the time

18    before that, not in the last nine years, but the time up until 1992,

19    including 1992.  Did state holidays exist, holidays prescribed by the

20    state when nobody goes to work?

21       A.   Yes, yes.  We did have state holidays, yes.

22       Q.   During those state holidays, and in addition to the state

23    holidays, were there religious holidays that were also deemed to be state

24    holidays when people didn't go to work?  Let me rephrase that question.

25    Do you remember up until 1992 which state holidays were celebrated in the

Page 2630

 1    country at the time?

 2       A.   Well, we didn't work for the New Year, we didn't work for the 29th

 3    of November holiday, the 7th of July holiday, the 4th of July holiday, and

 4    maybe several years.  I can't, perhaps, remember them all now.

 5       Q.   I hope that I won't be leading if I ask you whether May 1st -- the

 6    1st of May was a holiday, the state holiday too?

 7       A.   Oh, yes, the 1st of May, you're right.

 8       Q.   So those, then, were all the state holidays celebrated in the

 9    country at that time.  Was there a religious holiday amongst those state

10    holidays that you've just mentioned; were any of them religious?

11       A.   Well, we just didn't usually go to work.  If somebody was

12    celebrating his own family holiday, he would get a day off.  Now, if there

13    were four of us working, my colleagues, then if one of the ladies had her

14    own family holiday, she would get a day off and not come to work that day.

15       Q.   Mrs. Vasiljevic, yes, I know what you're saying that for the

16    Slava, the family religious holiday, it was provided by law that each

17    person could ask for a free day to celebrate his family holiday, but I'm

18    asking you about the state holidays now that which were the New Years, the

19    4th -- 1st of May, the 4th of May, and the 7th of May and the 29th of

20    November -- sorry, the 4th of July and the 27th of July.  Were any of

21    those dates religious holidays or were they only state holidays?

22       A.   I don't know.

23       Q.   Up until 1992, was it a state holiday?  Was the orthodox Christmas

24    a state holiday, did one -- did you go to work or not?

25       A.   Well, we never worked for Christmas, but I can't remember on the

Page 2631

 1    7th of January.

 2       Q.   But before 1992, you state that you didn't go to work.

 3       A.   No, Christmas was always a holiday.  All Serbs celebrated it and

 4    didn't go to work.

 5       Q.   Mrs. Vasiljevic, I can, perhaps, agree with you that all Serbs

 6    celebrated it, but I am asking you whether it was an official state

 7    holiday prescribed by the state?  Did the state prescribe, and I'm talking

 8    about up to 1992, that there was no work on Christmas.  Was that a

 9    state-prescribed holiday?

10       A.   I don't think the Serbs worked then.  I'm not quite sure.

11       Q.   Does that mean that the Muslims worked, for example, on that

12    holiday?

13       A.   Yes.

14       Q.   Was it a state holiday then or not?

15       A.   Well, the 4th of July was a state holiday with us.

16       Q.   Very well.  Very well.  Now, as the Holy Trinity day holiday is an

17    orthodox holiday and a Slava, asked by Mr. Groome -- in answer to

18    Mr. Groome's question you said that yes, it is an orthodox holiday but

19    that it wasn't your Slava.  Had it been your Slava, you would have

20    celebrated it?

21       A.   Of course.

22       Q.   Now, which is your Slava or the Slava observed by Mitar

23    Vasiljevic?

24       A.   Our Slava is St. George's day on the 6th of May.

25       Q.   Is that day called differently amongst the Serbs, is it called --

Page 2632

 1    is another term used to denote that particular day?

 2       A.   It is Djurdjevdan or St. George's Day.

 3       Q.   So it is Djurdjevdan?

 4       A.   Yes.

 5       Q.   And that is the Slava for which everybody could take a day off and

 6    not go to work and that that was customary; is that right?

 7       A.   Yes.

 8       Q.   Today is the 16th of November.  Is there a well-known Slava

 9    celebrated today?

10       A.   Yes.

11       Q.   Which Slava is it?

12       A.   Well, it's  Djurdjic, I don't know.  I know there are two that

13    come up very close to each other around this period.

14       Q.   Yes, it is Mr. Tanaskovic's Slava, but he has to work today.

15       A.   Yes.  Yes.  Djurdjic.

16       Q.   Did you mean to say to Mr. Groome that as the Holy Trinity was not

17    your family Slava, you had no particular obligations or responsibilities,

18    nor as is customary did you invite guests home?

19       A.   Of course.  If it is your own personal family Slava, then you

20    don't go to work.  Otherwise, you do.

21       Q.   When you explained all these customs and religious holidays, you

22    also mentioned that one could not do any house chores or engage in any

23    farming, so could you tell us which chores, which jobs could be performed

24    and which couldn't during those -- on those religious holidays?

25       A.   Well, if it was your Slava or some other holiday, for instance,

Page 2633

 1    one should not build a house or do any gardening, work in a shop or a

 2    hostelry.  I mean that has nothing to do with it and one can do it any

 3    day.  Or you can wash, you can clean, but on your Slava, on your saint's

 4    day, on your family saint's day, you shouldn't really do any housework or

 5    anything else.  You are there to meet your guests, to entertain your

 6    guests.

 7       Q.   Very well.  Mr. Groome asked you about what Mitar Vasiljevic did

 8    after 1992, what was his job then, and you did say something like that he

 9    worked for a while and then stopped.  Could you please be more precise?

10    There are different ways of not working, that is, there is a paid leave,

11    unpaid leave, or notice, that is being unemployed.  So what happened?  Did

12    he quit, did he take a leave, or was it something else?

13       A.   Mitar was on an unpaid leave because there were no salaries to

14    mention and he was -- he had nowhere to go, that is, there were no

15    salaries.  There was just a little bit of money.

16       Q.   And what did that mean, by statute?  What does an unpaid leave

17    mean?

18       A.   To be on an unpaid leave means that you are still formally

19    employed; that is, your years of service are still included, but you don't

20    go to work and you don't get any salary, of course.

21       Q.   Does this mean that his company paid all the fringe benefits,

22    except that he did not have to go to work, and at the same time he

23    received no remuneration, since it was an unpaid leave?

24       A.   Yes, that is right.  He did not go to work, but they paid his

25    social insurance, his health insurance, his pension insurance, but he did

Page 2634

 1    not get any salary.

 2       Q.   But did it happen once in a while that they would invite him back

 3    and that he would work, nevertheless, for a shorter or a longer period of

 4    time?

 5       A.   He went in case of a wedding or some party or some celebration,

 6    something like that; otherwise he didn't.  When there was more work

 7    involved.

 8       Q.   When Mr. Groome asked you about his revenue at the time,

 9    considering the situation, you literally said, "He served at weddings and

10    dispatches."  So will you please explain to us what do you mean by these

11    dispatches, or sendings-off, and what are these parties and what are these

12    festivities and how could he work there?  Was it private?  Who organised

13    those, and how could he work there?

14       A.   Well, one still does that.  Mitar was usually invited privately,

15    and he usually didn't charge for that if it was a close relative; distant

16    relatives, and of course from people who were complete strangers.  People

17    usually invite very many people, very many guests to these send-offs, up

18    to 500 people, so then he would go to work there.  And as I said, if it

19    was any of the relatives, then he wouldn't charge them anything, but

20    otherwise, if it was somebody strange and unrelated, then he would charge

21    for that.  Of course, I have very few relatives, so he didn't work for

22    them.

23       Q.   And on such occasions, when he did this privately, would he be

24    paid only in money, in cash, or would it sometimes be in kind too; that

25    is, would he be given perhaps some foodstuffs in remuneration?

Page 2635

 1       A.   Depends.  If, for instance, the chief host works abroad and he has

 2    lots of money, then of course he would pay cash; if not, then he would

 3    give him perhaps drink or meat, things like that.  It depended.  A shirt,

 4    perhaps, depending on what the host could afford.

 5       Q.   So if I understand, it varied, one case to the other, depending on

 6    who organised this party, and then he decided whether and what he would

 7    charge?

 8       A.   That's right.

 9       Q.   So he also -- he went to work at different fairs too, privately?

10       A.   That's right, yes.  He went around fairs.  Yes, he organised that.

11       Q.   Perhaps because this is yet another tradition and it doesn't exist

12    in all the countries all around the world, could you please explain what

13    is a fair and what do you do there, so that we could see what is it that

14    he could do there to make some money.

15       A.   Well, a fair is a country fair, where many people get together,

16    where you sing and dance.  Usually when something is being opened, for

17    instance, a church or a new school, then lots of people will get together

18    and there is a lot of food and drink going around, and Mitar would take

19    care of this catering, of the whole catering for such events.

20       Q.   And such fairs, apart from such events, that is, a new church or a

21    new school being inaugurated, would such fairs be organised on some

22    religious holidays too?

23       A.   That's right, yes.  Usually there would be such big celebrations,

24    big dos for religious holidays.  It was before the war and during the war

25    too.  Easter, for instance.

Page 2636

 1       Q.   Mrs. Vasiljevic, a few moments ago you were answering Mr. Groome

 2    and said that when it came to Mitar Vasiljevic's behaviour, he suffered a

 3    great deal when he saw wounded and crippled persons around him.  So my

 4    question is -- my question has to do with him as a host, as the lord of

 5    the house.  When he gets ready for a holiday, when you slaughter poultry

 6    or a lamb or a pig, does the host himself do it, and did Mitar Vasiljevic

 7    do that?

 8       A.   Well, the custom is, yes, to slaughter a lamb or a pig, but Mitar

 9    could never do that and we had to ask one of our neighbours to do it.  I

10    remember well when SFOR lived in our house, they wanted to celebrate

11    something and they wanted to have a roast lamb, and then we asked a

12    neighbour to do that, because Mitar could never bring himself up to

13    slaughtering a lamb or chicken or anything.

14       Q.   But was that, otherwise, a custom or not?

15       A.   Oh, yes, it was, for every Slava.  Always one would have either a

16    lamb or a pig or something.  But Mitar could never slaughter them.  We

17    usually asked one of the neighbours or his father or somebody.

18       Q.   I didn't ask you whether it was a custom to have that as one of

19    the courses.  My question was:  Isn't it customary for the father of the

20    family to do that?

21       A.   Well, yes.  Yes, that is so, but since Mitar could never bring

22    himself to do anything like that, then we always asked somebody else to do

23    that, whether it be a chicken or a lamb or a pig or whatever.

24       Q.   You also mentioned that his father did that too, isn't it?

25       A.   Yes.  He either asks his father, or his father simply does it.

Page 2637

 1    But Mitar never did it.  Mitar never slaughtered any animal.

 2       Q.   Do you know why was that?

 3       A.   Well, because he was averse to it.  He didn't like to do that.  He

 4    simply did not like that.  He was bothered by it.

 5       Q.   Just one more question.  When it comes to the place about which

 6    Mr. Groome asked you, and that is where he had been injured, did -- after

 7    that, did Mitar ever take you to that site and show you that place, or is

 8    it that you learned about it from his stories and from what other

 9    witnesses told you?

10       A.   Well, to be quite frank, I never really went to this spot, but

11    that he ever took me to the place and showed it to me, no.

12       Q.   But I assume you know the area quite well.  A moment ago you told

13    us that you worked on the square.  So was it that square, is it, that you

14    worked, somewhere near the place where he fell?

15       A.   That's right.  I worked nearby, but because he had gone to the

16    hospital, nobody ever showed it to me.  Sometimes as we would pass by,

17    Mitar would say, "Well, yes, that's where I fell," but that he ever took

18    me to the exact spot and pointed at it and said, "That's where I fell,"

19    no, he never did that.

20       Q.   Thank you, Mrs. Vasiljevic.

21            MR. DOMAZET: [Interpretation] I have no further questions

22                          Questioned by the Court:

23            JUDGE JANU:  Mrs. Vasiljevic, I would like to ask you:  Did people

24    in the shop where you used to work in 1992 ever discuss the death of

25    Mrs. Bahija Zukic?

Page 2638

 1            THE WITNESS: [Interpretation] I can't hear really.  Could you

 2    repeat, please?  I didn't hear anything.

 3            JUDGE JANU:  My question is:  Did people in the shop you used to

 4    work at in 1992 ever discuss the death of Mrs. Bahija Zukic?

 5       A.   No.  I don't even know whether she's alive or dead.  I have no

 6    idea.

 7        JUDGE JANU:  Thank you.  That's all.

 8        JUDGE TAYA:  Did you go to the Uzice hospital on the same day when you

 9    received a telephone call about the injury of your husband?

10       A.   No.  No, I didn't go the same day.

11            JUDGE TAYA:  Why you didn't go on the same day?

12       A.   Well, I did not have a car and I had small children, so I had to

13    find somebody to look after them and until I found somebody who would be

14    with my children and where -- to whom to take them, I could not go.

15            JUDGE TAYA:  But you said you received the telephone call

16    approximately at 8.00 so if you had any intention to go to, it was

17    possible to go to the Uzice hospital on the same day?

18       A.   Well, I don't think I would have managed to find a car that night

19    or something.  I don't know whether there was any kind of public

20    transport.  I don't think there was any public transport at the time to go

21    through Visegrad.

22            JUDGE TAYA:  When you went to the Uzice hospital, you went by car?

23       A.   Yes, I went by car when I took Mitar out of the hospital.

24    Otherwise -- well, I don't know.  At times it could have been that I went

25    by bus and perhaps sometimes I went by car.

Page 2639

 1         JUDGE TAYA:  How many minutes did it take to go to the Uzice hospital

 2    from your house or from the centre of Visegrad approximately?

 3       A.   Well, it depends on the means of transportation.  It depends

 4    whether there are any delays, whether it's a bus that you're taking or a

 5    car.  Well, I think about two hours.  I think at least two hours.  I think

 6    that now if you take a bus, then it would take you two hours now, but at

 7    that time there were many delays because the war was on at the time so I

 8    don't really know how long it took.

 9            JUDGE TAYA:  Your house is close to the house of Dragan Tomic, the

10    commander of the police?

11       A.   No, no.  It's the same street, about 100, 200 metres away from our

12    place.  We have to pass by his house on our way to the town.

13            JUDGE TAYA:  How do you characterise the relationship of Mitar

14    Vasiljevic with Dragan Tomic, the commander of the police?  It was good,

15    intimate or other; how do you characterise?

16       A.   Dragan Tomic was a very, very nice man.  So we were on good terms

17    with him always.  Mitar, I don't know, all of us, we were all on good

18    terms with him.  He was a very nice man indeed.  I can tell you only all

19    the best about him.  I don't know what else to say.

20            JUDGE TAYA:  Your husband Mitar Vasiljevic had particularly good

21    relationship with Dragan Tomic, other than the other neighbours?

22       A.   Why of course.  I mean they were on very good terms like everybody

23    else was.  Everybody was friendly with him.

24            JUDGE TAYA:  Thank you.

25            JUDGE HUNT:  Have you any questions arising out of that,

Page 2640

 1    Mr. Groome?

 2            MR. GROOME:  No, Your Honour.

 3            JUDGE HUNT:  Mr. Domazet?

 4            MR. DOMAZET: [Interpretation] Only one, Your Honour and it has to

 5    do with the question of whether there was a house across the street from

 6    the Vasiljevic house.

 7                          Further Re-examination by Mr. Domazet:

 8       Q.   Perhaps in view of some other explanations, I should like to ask

 9    Mrs. Vasiljevic to explain if across the street from their house.  Are

10    there any houses there and if not, then why?

11       A.   Well, across the street from my house, no.  Next to my house is

12    the creek and there's Dr. Dragan's house.  And across, opposite from our

13    house is the Drina so there can't be any other houses.

14       Q.   Yes.  In the street, the houses are on only one side of the street

15    because on the other side of the street borders on the Drina River?

16       A.   That's right.

17            JUDGE HUNT:  Thank you, madam, for the evidence you have given and

18    for coming here to give that evidence.  You are now free to leave.

19                          [The witness withdrew]

20            JUDGE HUNT:  Now, Mr. Domazet, we've got your list of witnesses

21    for next week.  You will recall that when we were discussing Friday of

22    next week, and I told you that there was a plenary meeting of the Judges

23    in the morning that we would give you the afternoon off depending upon the

24    speed with which we have been travelling.

25            Now, I have to say that we have not been travelling as quickly as

Page 2641

 1    I had anticipated.  I think that in those circumstances, we will certainly

 2    resume the trial next Friday after the Judges have finished their

 3    meeting.  It may mean that you may have to wait a little while seeing we

 4    have six new judges.  I don't know how long they're going to talk for, if

 5    they're going to talk at all, but at the moment, it is due to start at

 6    9.30, I think, and I suggest that you be ready to proceed at 11.30 and

 7    we'll certainly fill in the rest of the morning and the afternoon,

 8    certainly we'll be hearing evidence.  So you better get some more

 9    witnesses along for next week.

10            I'd do that, and I should explain this, as I think I have

11    indicated before.  We are under a very strict time constraint in relation

12    to this trial.  It was stated that we would finish it this year and I have

13    a terrible feeling at the moment that we will not unless we spend every

14    moment of the time available with the trial.  Of course depending upon

15    Mr. Groome's response to the questions I asked him yesterday, it could be

16    that there will be less witnesses to be called, but at this stage, I must

17    assume that the Prosecution case is as it was opened which, unfortunately,

18    will require you to call the eight witnesses who will simply say that your

19    client was in hospital in Uzice.

20            Well, now, I don't think it's worth while trying to start another

21    witness now.  We will resume again at 2.30.

22                          --- Luncheon recess taken at 1.00 p.m.

23

24

25

Page 2642

 1                          --- On resuming at 2.30 p.m.

 2            JUDGE HUNT:  Where is the witness?

 3                          [The witness entered court]

 4            JUDGE HUNT:  Now, sir, would you please make the solemn

 5    declaration in the document which the usher is showing you.

 6                          WITNESS:  WITNESS VGD23

 7                          [Witness answered through interpreter]

 8            THE WITNESS: [Interpretation] I solemnly declare that I will speak

 9    the truth, the whole truth, and nothing but the truth.

10            JUDGE HUNT:  Sit down, please, sir.

11            Mr. Domazet.

12            MR. DOMAZET:  Thank you, Your Honour

13                          Examined by Mr. Domazet:

14       Q.   [Interpretation] Good afternoon, sir.

15       A.   Good afternoon.

16       Q.   You will be shown the pseudonym we'll be referring to you, as

17    we're not going to be using your name and surname.  Could you please tell

18    us whether your real name is on the piece of paper that the usher is going

19    to now show you and that your number is VGD23.

20       A.   Yes, it is.

21            JUDGE HUNT:  What's your next number as an exhibit?

22            THE REGISTRAR:  D24.

23            JUDGE HUNT:  Thank you.  My concern is I know what the last one

24    was, but you may reserve them.

25            MR. DOMAZET:  Yes.

Page 2643

 1            JUDGE HUNT:  That will be Exhibit -- D24 and it is under seal.

 2            MR. DOMAZET: [Interpretation]

 3       Q.   VGD23, I'm going to start my examination-in-chief, and I'd like to

 4    ask you your particulars, but when you tell us, could you be careful not

 5    to jeopardise your protected identity.  Could you tell us where you were

 6    born, please.

 7       A.   I was born in the village of Strazbenice, the Visegrad

 8    municipality.

 9       Q.   How old are you?

10       A.   I am 46 years old.

11       Q.   What ethnicity are you?

12       A.   I'm a Serb.

13       Q.   What education do you have?

14       A.   I completed secondary school.

15       Q.   Where and when did you begin working after you had completed your

16    education?

17       A.   That was in 1976.  I started working in Visegrad, [redacted]

18    [redacted].

19       Q.   Did you live and work in Visegrad from that time until the present

20    day?

21       A.   Yes.  I worked in the same institution from 1976 to the present

22    day.

23       Q.   In view of the fact that you worked in the [redacted] from 1976,

24    I should like to ask you to explain the following:  If you look at the

25    period up until 1990 or 1991, how did the police force function?  What was

Page 2644

 1    the set-up, and were there any differences, especially from that period to

 2    the spring of 1992?  Could you tell us briefly something about that,

 3    please.

 4       A.   From 1976, right up until about the time that the national parties

 5    were formed, the work of the police force was based partially - not

 6    partially - almost 100 per cent, I would say, on the rules and regulations

 7    governing the police force and police procedure.  However, for the period

 8    that followed that, I couldn't claim that that was true.

 9            I omitted to answer one of your questions, I think.  Let me say

10    that I worked in a [redacted]

11    [redacted], and a third of them were Serbs and

12    two-thirds of the policemen there were Muslims, which more or less

13    reflected the percentage and ratio of the ethnic groups in Visegrad

14    municipality.

15       Q.   So at that time, the national composition of the municipality was

16    in that ratio, and this was reflected in the police force as well; is that

17    right?  That is right, I take it.  Now, were there any special problems?

18    When I say "problems," I don't mean the standard type of thing one

19    encounters in a police force, but in a nationalistic sense, before the

20    multiparty elections.

21       A.   No.  I'm not aware of that.  I'm not aware of any drastic example

22    of anything like that, any internationality or interethnic -- how can I

23    call that? - excessive behaviour or anything like that during that

24    period.  I'm not aware of it.

25       Q.   Would you say that the work of the police force at that time,

Page 2645

 1    given the multi-ethnic composition, was effective, efficient, and no

 2    problems?

 3       A.   I claim that with full responsibility.  Yes, it was like that.

 4       Q.   Can you tell us now something a little more about the state of

 5    affairs after the multiparty elections took place in Bosnia-Herzegovina,

 6    what was the situation like then?

 7       A.   Well, with the formation of the national parties themselves, the

 8    SDA to begin with, there was a disruption, an upset, and -- of interethnic

 9    relations and this was reflected in the police station as well.  Some

10    things began to happen which were absolutely foreign to us until that

11    time.  We weren't accustomed to those kinds of things taking place, at

12    least not in the environment in which I had lived and work up until that

13    time.

14       Q.   Can you tell us, please, or rather can you give us an example

15    which would be characteristic for those types of changes in the

16    relationships that you have just told us about?

17       A.   Well, let me start with the formation of the nationalist parties

18    themselves.  There was public rallying of citizens when the parties were

19    established, and a change took place, the security and traffic regulation,

20    for example, and the regulation of other affairs which comes under the

21    exclusive competence and authority of the police force began to be

22    organised on a self-initiative basis.  They began to organise their own

23    services.  And then traffic signs were destroyed, graffiti was

24    predominant, posters were stuck up haphazardly over shop windows and the

25    facades of houses and in other visible prominent spots on the roads as

Page 2646

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Page 2647

 1    well.

 2            Later on, the first more serious excesses and incidents took place

 3    which largely disrupted and upset interethnic relations.

 4       Q.   Before I ask you something about that, about the outbursts and

 5    excessive behaviour, can you tell us something that you just said, you

 6    mentioned graffiti, posters stuck on the walls of houses and buildings,

 7    what kind of graffiti?  What kind of posters?  What was written on them

 8    which could lead and cause this disruption?  What were they about?

 9       A.   At the beginning, there was graffiti which glorified the party

10    concerned, that is to say, the SDA party and appealed to its members to

11    vote for it.  But later on, this grew into graffiti which were threatening

12    in nature and they were addressed to the Serb people.

13       Q.   The first point you made is certainly something that is allowed,

14    that is to say, parties can advertise themselves in the way you have

15    described, but what you said occurred later on, I'd like to hear a bit

16    more about that, please.  What happened later on?  Because you said that

17    there were some graffiti addressed to the Serb people, what slogans were

18    written up this way?

19       A.   Well, I can't give you quotations now, but actually it said,

20    "Serbs, what are you waiting for, Chetniks?"  They were insulting

21    slogans.  "What are you looking for in these regions?"  And things like

22    that, "What are you doing here?"  And so on.  There were lots of others

23    too.  One of them was one which said, "It's not 1941 anymore."  Things

24    like that.

25       Q.   Slogans, graffiti, posters of this kind, did they have an effect

Page 2648

 1    on interethnic relations and disrupt them; that is to say, how did the

 2    Serbs take to these things in Visegrad?  What did they think of them?

 3    What was their reaction?

 4       A.   Well, messages and slogans of this kind wouldn't be well-received

 5    by anybody and so the Serb people were not happy to see them.  They felt

 6    the Serb people felt jeopardised, threatened in a way.  And later on, the

 7    Serb Democratic Party was established, the SDS.

 8       Q.   Which party was formed first in Visegrad after the multiparty

 9    elections -- rather prior to the multiparty elections, which party was

10    formed first?

11       A.   In Visegrad, the first party to be formed was the Party of

12    Democratic Action or the SDA party.

13       Q.   To the best of your recollections, how soon after that -- how long

14    after that was the SDS, the Serb Democratic Party formed?

15       A.   Well, I can't quite remember, but certainly -- well, I can only

16    give you an approximation.  Several months went by before, so not the

17    following month, but maybe even six months later.  I can't give you an

18    exact time.

19       Q.   Very well.  At the time, did any parties exist or were they

20    operating that were not national parties, ones which tried to maintain the

21    interethnic community and who had members of the different ethnicities,

22    both ethnicities, in fact, as their members?

23       A.   Yes.  That was the SDP party, and I think, as if I remember

24    correctly, that the SDP had a rally at the sports centre and I think that

25    took place before the SDS party was formed.  And also in Visegrad, there

Page 2649

 1    was the Reformist Party of Ante Markovic, I think that's what was its

 2    name, and that party too had supporters.

 3       Q.   Now, the two parties that you mentioned, those last two, were they

 4    successful in the multiparty elections, especially for the Visegrad area,

 5    as far as Visegrad is concerned?

 6       A.   They, that is to say the number of voters, came after the national

 7    parties which means that the order was the SDA, the SDS, and then the

 8    rest, the other parties.  The SDA, the SDS and then the rest.

 9       Q.   The order you stated, was that the majority vote, does it -- do

10    you mean that the SDA won the elections, the multiparty elections?  Did

11    they get the most number of votes in Visegrad?

12       A.   Yes.

13       Q.   What you were talking about a moment ago about graffiti and

14    posters and the fact that they created tensions, does that relate to the

15    time before the elections or after the elections, or both those periods,

16    both before and after?

17       A.   I think that the problem became more serious after the advent of

18    the SDA party, after the SDA party came to power in Visegrad municipality.

19       Q.   So in your opinion, it was after the elections and the arrival of

20    the SDA in Visegrad that the situation deteriorated.  Have I understood

21    you correctly?

22       A.   Yes, that's right.  It was much, much more marked than it had been

23    in the pre-electoral period.

24       Q.   You explained to us a moment ago that before the elections, that

25    prior to the elections, in the police force, the ratio of policemen

Page 2650

 1    reflected the national structure or ethnic structure of the municipality

 2    itself and that everything functioned properly.  Now, was there a similar

 3    ratio in the other government organs, local organs of power and authority

 4    in Visegrad?  I'm talking about the period before the multiparty elections

 5    now.

 6       A.   Yes.  The posts and functions were distributed according to what

 7    we used to call the key, the national ratio, or national key, we used to

 8    call it.

 9       Q.   Now, could you explain what the national key meant?  Did it mean

10    proportionate representation of a certain nation or ethnic group on the

11    territory, or something else?

12       A.   The percentage composition of the municipality according to the

13    national structure was represented both in the organs and institutions

14    that existed in the municipality and the Municipal Assembly.

15       Q.   Could we say in more simple terms that it was a -- that two-thirds

16    of the population -- that two-thirds of the cadres were Muslims, according

17    to that key, and one-third of the cadres were Serbs, according to the

18    national figures?

19       A.   Yes, that's right.

20       Q.   What about after the multiparty elections, when the new

21    authorities came into being?  What happened then?

22       A.   According to the electoral results, the results of the first

23    multiparty elections, the SDA party in Visegrad had an assembly majority

24    of over half, and then this parity ratio was upset in the government.  I

25    think that at the first assembly, when the multiparty assembly was

Page 2651

 1    actually set up, outside legal procedures that had been established

 2    earlier on, and bypassing those procedures, a vote was taken, and there

 3    was an ordinary majority vote in the Municipal Assembly, by a simple

 4    majority, which meant that absolute power was taken over by the SDA.

 5    There was a simple majority vote.

 6       Q.   If I followed you, what you're saying is that there was a change

 7    in the statute of the municipality, stating -- with a simple majority.

 8    Does that mean that there should have been a qualified majority, that some

 9    other two-thirds majority vote was needed, or some other, and that the new

10    authorities did not respect that?  Is that what you're saying?  Did I

11    understand you to say that?

12       A.   Yes.  Up until then, there was always a two-thirds majority vote

13    that carried, and that was in line with the Statute of the Municipal

14    Assembly.  However, on that occasion, everybody said there was an illegal

15    procedure that was applied, and what was introduced was a simple majority

16    vote, which meant 51 votes, 50 plus 1, 51 votes as a simple majority.

17       Q.   And this referred to questions and issues that had to be solved by

18    a two-thirds majority vote before that; is that right?

19       A.   Yes, precisely so.  That's how it was.

20       Q.   Could you tell us, please, what this led up to?  Give us some

21    characteristic examples of the repercussions that this establishment of

22    power had, in brief terms, if you're able to.

23       A.   With the establishment of the new government, the new authorities,

24    we saw the first unfortunate events unfolding.  One of the most drastic

25    examples which I wish to stress was that Serbs were stopped in their

Page 2652

 1    cars.  They were pulled out of their cars, they were beaten on the spot;

 2    that is to say, they were physically attacked.  Next, buses would be

 3    stopped which were coming from Serbia proper.  The passengers would be

 4    ill-treated.  Then military vehicles would be stopped and the soldiers

 5    would be mistreated.  They would be physically attacked.  Then killings

 6    took place.  That is to say, the killing of a Serb took place in a

 7    village.  The village was Crncici.  The Serb flag was burnt on Visegrad

 8    square, and policemen were held prisoner in the police station if they

 9    were Serbs.  They were detained in the station.  People opened fire on the

10    police station.  Firearms were used.  Barricades or roadblocks were set up

11    along the certain roads and roads leading up to the settlements, and

12    things like that.

13            JUDGE HUNT:  Now, Mr. Domazet, Judge Janu wants to clear something

14    up about what you said a moment ago.

15            JUDGE JANU:  Just to understand what was said before Mr. Domazet,

16    would you be so kind and clarify it for the Chamber what was the character

17    of the electoral system of the country at that time was that electoral

18    system changed before the multiparty elections or was the electoral -- was

19    the electoral system the same before multiparty elections and after or was

20    it changed?  That's my question.  Thank you.

21            MR. DOMAZET: [Interpretation] Thank you, Your Honour.  I will ask

22    the witness to answer that question.

23       Q.   I suppose you understood that question.  Will you tell us if

24    before the multiparty elections, the electoral system, they took any

25    change, that is, as applied to Visegrad, did the -- was the municipal

Page 2653

 1    statute that you mentioned changed before the multiparty elections or

 2    after them?

 3       A.   If you are referring to the ratios or rather the two-third

 4    decision making or just simple majority voting, this particular change

 5    took place afterwards; that is, in that regard, this statute was changed

 6    following the multiparty elections.

 7            When the assembly was constituted ...

 8       Q.   Let's try this way.  So the new local authority that was set up

 9    following the outcome of the elections, did they find their statute in

10    force according to which important matters, matters relative to ethnic

11    equality were to be settled by two-thirds majority and that the new

12    assembly then changed it into a simple majority; is that it?

13       A.   That's right.  The new assembly changed that and said that simple

14    majority, that is, 50 plus one vote were sufficient to take decisions on

15    such matters.

16            MR. DOMAZET: [Interpretation] Thank you.

17            JUDGE JANU:  My question led to another point because in our

18    system, there is an electoral law for the general elections and electoral

19    law for the municipal elections and my question was:  Was this change

20    which the assembly -- after the municipal assembly after the multiparty

21    elections has done, was it the change of general law passed by the

22    parliament of the country, or was it just change which the assembly could

23    have done by its own authority?

24            So maybe the witness is not able to explain it to me, but to have

25    all this evidence and to be able to evaluate it, this is a crucial point.

Page 2654

 1    You both are lawyers, so you understand.  Thank you.

 2            MR. DOMAZET: [Interpretation] Yes, I do understand that.

 3       Q.   Now, witness, I suppose you understood that question, but do you

 4    know the answer to it; that is, were the changes due to the changes

 5    adopted and approved by the parliament of Bosnia-Herzegovina?  Do you know

 6    if that went in line with the changes that took place in

 7    Bosnia-Herzegovina either prior to or following the multiparty elections?

 8       A.   The municipal statute is adopted by the municipal assembly and the

 9    municipal assembly is the one which changes the statute, that is, the

10    councilmen at the municipal, at the session of the municipal assembly.  In

11    other words, the republic and the state parliament does not impose the

12    municipal statutes of the municipalities but, on the other hand, these

13    statutes must be in conformity with the constitution.

14       Q.   And that, I think, was the purpose of the question.  Was the

15    constitution changed to this effect which would then allow the change --

16    this change in the statute?  Do you know that?

17       A.   I think not.  Because had that been done, it wouldn't have been

18    unlawful, and I did point out that this change of statute was not lawful.

19       Q.   Yes, you did that, but shall I say that is what the Serb side, if

20    I may call it that, thought of it.

21       A.   Yes, that's right.

22       Q.   I'd like you to go back again to that period of time, that is, the

23    new government, but in the police in which you continued working.  Will

24    you tell us briefly how did this new authority affect the work of the

25    police and then extending it to the general interethnic relations in

Page 2655

 1    Visegrad?

 2       A.   When the new assembly was constituted, and when the already

 3    mentioned decision-making system was introduced, it was bound to find its

 4    reflection in the police station as well.  The cadres were changed, that

 5    is, the executives were new.  The former chief of the public security

 6    station who was a Serb, he was removed and replaced by an SDA man, and

 7    that is a man who was a Muslim, that is, man number one in the police

 8    station was now a Muslim.

 9            The Serb officers, not only Serb, I'm sure, but Muslim too who had

10    been doing their work professionally until then were -- also fell victims,

11    if I may put it that way, of that new authority, that is, individuals were

12    dismissed and assigned to lower-ranking posts or lost their jobs

13    altogether.  And that was a tool of, if I may call it that, that is, those

14    people were unassigned, that is, they were receiving their salaries but

15    they did not come to work and they were called unassigned personnel.

16       Q.   You mean after the change and after the change of government, that

17    many Serb policemen, but not only Serb, Muslim too, those who were good

18    professionals, that they were removed or demoted or rather that they did

19    not perform the jobs any longer even though they continued getting their

20    salaries; is that it?

21       A.   No, it was only, at least in my police station, it affected only

22    the Serbs.

23       Q.   Now, tell me about this:  Weapon permits, even hunting weapons and

24    ammunition and all that, that fell under the jurisdiction of the police,

25    isn't it?

Page 2656

 1       A.   That's right.

 2       Q.   Did the situation in this field change too?  We know that this is

 3    a particularly sensitive area, especially in a multiethnic environment

 4    such as Visegrad.

 5       A.   Yes.  I remember a briefing at which -- and this was one of the

 6    items on the agenda of that briefing, what had happened -- well, I'm not

 7    quite sure, but of about 105 applications resolved over a period of time,

 8    100 were -- concerned the applicants who were Muslims and negligible part

 9    of applications resolved and approved came from Serbs and the same held

10    true of the applications for the purchase of firearms and permits for the

11    purchase of ammunition.

12       Q.   When you mentioned these figures, does this mean not applications

13    submitted but applications which were resolved in the affirmative way?  Is

14    that people who were authorised, who were allowed to buy their weapons or

15    ammunition?

16       A.   Yes.  These were the applications that were granted, these

17    applications for the purchase and licences for weapons and ammunition were

18    the ones which were granted.  There must have been more applications than

19    that.

20       Q.   And at that time, was there unlawful arming of people?  Did you

21    receive any information about that in your police station?

22       A.   I am sure that, yes, people were arming themselves unlawfully,

23    because from time to time one could hear fire open from various firearms,

24    in all parts of the municipality.  One could hear whole rounds of fire, so

25    that it was easy to infer from that that somebody was procuring weapons

Page 2657

 1    unlawfully, because automatic weapons cannot be bought by anyone legally,

 2    lawfully.

 3       Q.   And you personally, and your [redacted], did you take any

 4    steps in that regard?

 5       A.   Nothing special was done, and even, although we had received

 6    information that some policemen were participating in the distribution of

 7    these unlawful weapons and ammunition, even then, nothing was done.

 8       Q.   Those policemen about which you had learnt that they were

 9    participating in that, were they Muslims or Serbs, or both?

10       A.   Muslims.  On one occasion they were caught red-handed taking the

11    ammunition from the police station.  Yes, taking the ammunition from the

12    depot in the -- from the storage room in the police station.

13       Q.   Were they then arrested and was the investigation undertaken

14    against them?

15       A.   No, they were not arrested and no proceedings were launched, even

16    though we knew exactly who they were; that is, we knew their full names.

17    The Ministry of the Interior was notified about this, and that was when

18    the first major misunderstandings between policemen who were Serbs and

19    policemen who were Muslims began.  A group had come to a briefing, because

20    after that incident, Serb policemen - [redacted]- after that

21    incident, Serb policemen refused to go on working with policemen who had

22    been caught red-handed, that is, illegally taking away, or rather, simply

23    stealing the ammunition from the storage room in the police station.

24       Q.   Was it then that the Serb police separated, parted company with

25    the Muslim part of the police?  We've already heard here about this from

Page 2658

 1    some other witnesses.

 2       A.   And then a period of time ensued when the Serb policemen did not

 3    come to work.  We requested that the policemen who had done that be

 4    disciplined and be removed from the police station.

 5       Q.   And did this happen or not?  Tell me, yes or no.

 6       A.   No.

 7       Q.   You mentioned as one of many incidents the capture of Serb

 8    policemen.  Will you now, please, as briefly as possible, will you tell us

 9    who did that, when did it happen, and what was it all about?

10            JUDGE HUNT:  Mr. Domazet, this is precisely the material which you

11    said was going to be dealt with very generally, and although you continue

12    to use the word "briefly" in your questions, the answers are anything but

13    brief.  Now, the relevance of it has never been made clear.  I understand

14    you want to get this witness through by the end of the afternoon.  You're

15    not going to get anywhere near it if you continue with this irrelevant

16    material.  We are concerned with the attacks upon the Bosnian Muslim

17    civilian population, not with the attacks upon the Bosnian Serbian

18    civilian population.  It's a matter for you, but it seems to me that you

19    have gone way beyond what you said you were going to do.

20            MR. DOMAZET: [Interpretation] Your Honour, I have only a few more

21    questions, because the witness is well informed about these events.  And

22    the incident I just mentioned is something that happened on the eve of the

23    Uzice Corps arrival, that is, precisely at that time, and many witnesses

24    of the Prosecution tried to somehow disregard these events, and all I

25    wanted this witness to do was explain it to us.  We have another witness

Page 2659

 1    who is protected.  I'd like to show the name of this witness to this

 2    witness because I'll have to refer to him and I do not want to mention his

 3    name.  But I only have a few questions more for this witness and then I

 4    will be over.  This should be VGD25.  I should like to tender it into

 5    evidence and I'd like to have one copy of this shown to this witness.

 6            JUDGE HUNT:  VGD25.  Is that going to be Exhibit D25,

 7    Mr. Domazet?

 8            MR. DOMAZET:  Yes, yes, yes.

 9            JUDGE HUNT:  That will be Exhibit D25, and it is under seal.

10            MR. DOMAZET: [Interpretation] May I continue?

11            JUDGE HUNT:  Yes.

12            MR. DOMAZET: [Interpretation]

13       Q.   Have you had a look at the name of this witness?  If you want to

14    mention him, then please refer to him under the number indicated next to

15    him, which is VGD61 [as interpreted].  Did you know this person?

16       A.   Yes, I did. [redacted]

17       Q.   Was he involved in any of the incidents which took place at that

18    time, which is April 1992?

19       A.   As far as I know, in April 1992, when the conflict broke out,

20    VGD25, [redacted]

21    [redacted],

22    [redacted].

23       Q.   And what happened then?

24       A.   According to eyewitnesses, that same evening -- that same day, in

25    the evening of that same day, as day set, he fled to a locality which was

Page 2660

 1    ethnically Muslim and where he anyway worked, because, that is, he was the

 2    leader of the sector, for that particular sector.  In other words, his job

 3    assignment was there and he knew people in that locality.

 4       Q.   And that was the locality of --

 5       A.   Medjedja, it is a neighbourhood community comprising several

 6    hamlets.  So it is the neighbourhood community of Medjedja with a number

 7    of hamlets.

 8       Q.   And just one more question, related question, do you recall if he

 9    was called to account, if he was ever brought to justice?

10       A.   No, he was never brought before court nor have ever any steps been

11    taken in this regard.

12       Q.   And outside of all of that and respective of all these situations,

13    let me ask you, did you know or do you know Mitar Vasiljevic?

14       A.   I know Mitar Vasiljevic.  I've known him for some 30 years or so,

15    25, 30 years.

16       Q.   Did you ever have the opportunity to see him in May/June 1992?

17    Did you hear anything about him at that time in view of your job?

18       A.   At that time, I was performing my job in the field so that I

19    wasn't all that often in the town itself, but my wife who is a salesperson

20    in the centre of the town, in a shop there, told me that sometime in

21    mid-June, thereabouts, he had organised the cleaning of the town.  My wife

22    was one of those who took part in that cleaning of the town.

23       Q.   Does that mean that you never saw him at that time?

24       A.   That's right.  I did not see him at that time.

25            MR. DOMAZET: [Interpretation] Thank you very much.  I do not have

Page 2661

 1    any further questions of this witness, Your Honour.

 2            JUDGE HUNT:  Cross-examination, Mr. Groome.

 3            MR. GROOME:  Can I ask that the ELMO just be pushed back a bit.  I

 4    can't see the witness.

 5                          Cross-examined by Mr. Groome:

 6       Q.   Sir, in connection with your duties [redacted],

 7    did you ever have occasion to accompany convoys of Muslims who wished to

 8    leave the area?  Did you ever do that perhaps to provide protection for

 9    them?

10       A.   I did once.

11       Q.   Can you tell us where that was or when that was, I'm sorry.

12       A.   I can't remember the date.

13       Q.   Was it during the summer of 1992?

14       A.   Yes, it was in 1992.

15       Q.   And was -- were these Muslims leaving voluntarily or were they

16    being forced to leave Visegrad?

17       A.   As far as I saw, and the convoy that I accompanied, escorted, it

18    was women, children, and elderly persons who were voluntarily, they

19    voluntarily wanted to leave Visegrad and go to Central Bosnia because

20    probably they felt safer there because I, too, had sent my children to

21    Serbia and left them with relatives because I thought that they'd be safer

22    there.

23       Q.   Now, was I correct in thinking that you accompanied this convoy to

24    protect them?  Is that why you accompanied this convoy?

25       A.   That was my job to ensure the security of these people with the

Page 2662

 1    other members of the escort, that is to say, to escort them safely and

 2    securely through Serb settlements.

 3       Q.   Well, why did they need to be protected as they travelled through

 4    Serb settlements?

 5       A.   At that time in those parts, there were paramilitary units or

 6    groups.  So not only was there a threat from those quarters to a Muslim

 7    convoy, but it was a threat to the Serbs too.

 8       Q.   Let me ask you a question:  At some point during this period,

 9    checkpoints were set up all around the town; is that correct?

10       A.   I'm not aware of that.  I didn't see them.  I don't know.

11       Q.   Would it be fair to say in your job [redacted] you travelled

12    around the town; is that correct?

13       A.   During that period, I was not performing my usual [redacted].

14    I was positioned more on roads providing security, and the main road, you

15    know, runs through Visegrad.  There are a number of regional roads and

16    local roads so that mostly I was providing security for those roads.

17       Q.   And if you saw somebody on one of the roads that you are

18    protecting and that person does not have -- I'm sorry, and you do not

19    recognise this person, would you ask to see this person's identification

20    papers?

21       A.   No, I wouldn't, unless he were armed or something like that.  I

22    don't know everybody, so if -- unless somebody is suspicious in any way.

23       Q.   Let me come back to my earlier question.  Since you were one of

24    the people protecting the roads, you, better than anybody, should know

25    whether or not at any time during this period, there were checkpoints

Page 2663

 1    along those roads.  At any time during the summer, spring and summer of

 2    1992, were there checkpoints along the roads in and out of Visegrad?

 3       A.   I'm not aware of that.

 4       Q.   Thank you.  Now, I want to come back to this convoy that you

 5    escorted.  Can you give us an idea of how many people, how many women,

 6    children, elderly altogether, about how many people were in this convoy?

 7       A.   There were three buses and two trucks.

 8       Q.   And how many police were with you protecting that convoy?

 9       A.   Not all of us were policemen.  Everybody providing the convoy's

10    security, members providing security for the convoy, there were ten of us,

11    which meant two for each vehicle.

12       Q.   And can you give us an idea of how many of those ten were

13    policemen?

14       A.   I can't even remember the names of those ten, but as far as I

15    recall, [redacted]

16    [redacted]

17       Q.   And I take it from your answer that you do not remember the names

18    of the other men who were with you protecting that convoy, do you?

19       A.   Well, I know four or five of them.  Do you want me to start

20    enumerating?  I don't know all their names, but four or five, because nine

21    years have gone by since then.

22       Q.   I understand.  If you could give us the five, we'd be grateful.

23       A.   There was Andric who died later, who was killed later on.  There

24    were two Simsic men, there was Goran.

25       Q.   Can you tell us Goran's last name?

Page 2664

 1       A.   Nedic.  He didn't work as a policeman, he was one of the staff at

 2    the police station before the war, an employee of the police station but

 3    not a policeman.

 4       Q.   Let me ask you this: [redacted], were you the person

 5    who organised the security for the convoy?

 6       A.   No.  I didn't organise it.  We were assigned the duty of providing

 7    security for the convoy.

 8       Q.   And who assigned you that duty?

 9       A.   I was assigned that duty by the commander of the police station.

10       Q.   And can you tell us that person's name?

11       A.   Dragan Tomic.

12       Q.   The other men who weren't policemen, were they armed during this

13    duty to protect this convoy?

14       A.   Yes.

15       Q.   And what kind of weapons did they have?

16       A.   They had automatic rifles.

17       Q.   And who issued them these automatic rifles?

18       A.   I don't know that.  I can't answer that.  I don't have that

19    knowledge.

20       Q.   Where were you escorting the convoy to?

21       A.   The convoy was going from Visegrad, via Rogatica and Sokolac and

22    Knezina, towards Olovo.

23       Q.   And Olovo, it's actually a mountain, the place called Mount Olovo;

24    correct?

25       A.   Olovo is a municipality.

Page 2665

 1       Q.   Now, in the course of your duties as a [redacted], did you

 2    ever have to arrest Muslim extremists?

 3       A.   I never received orders like that.

 4       Q.   Well, surely at some point in time, protecting the security of the

 5    roads and the town, you must have arrested somebody who was doing

 6    something illegally, did you not?

 7       A.   If you mean criminals, then yes, but they weren't extremists.

 8    They are two different concepts in our country, extremists and criminal,

 9    two different things.

10       Q.   Can you tell us approximately how many -- or what would be an

11    average number of criminals who were Muslims would you arrest per month

12    during this time period, April to August of 1992?

13       A.   From April 1992 to what month?  I didn't understand what you

14    said.

15       Q.   August of 1992.

16       A.   No, I didn't have a single occasion to arrest anyone, to arrest a

17    Muslim during that period of time.

18       Q.   Were you ever given the responsibility of supervising the

19    detention of Muslim criminals or extremists who may have been arrested

20    during that period?

21       A.   No.

22       Q.   Did there ever come a time when you became aware that the SDS

23    party was distributing weapons to Serbs in and around Visegrad?

24       A.   No, never.  I never learnt information to that effect.

25       Q.   Had you learned such information, would you have acted upon it?

Page 2666

 1       A.   I would write an informative report to my superior.

 2       Q.   Now, you mentioned a few minutes ago about paramilitaries in the

 3    area.  Were these Muslim paramilitaries, Serb paramilitaries, or both?

 4       A.   My claim was not based on my own personal observations.

 5       Q.   You've given us a rather extensive overview of the situation in

 6    Visegrad and your beliefs regarding the cause of the problems in

 7    Visegrad.  I want to read you a portion of a statement by another Serb

 8    just like yourself, approximately the same age as you, and ask you, is

 9    this not a more accurate account of how the problems occurred in Visegrad:

10            "In the early part of April of 1992, Perisic Risto, one of the

11    leaders of the SDS and the head of the public security station, met with

12    this Serb witness and said that he was going to ask the Uzice Corps to

13    intervene in Visegrad.  On the 12th of April, 1992, Perisic Risto led

14    approximately 3.000 soldiers from the Uzice Corps into Visegrad.  These

15    troops were joined by the volunteer units led by Jeftic Dejan."

16            Do you know that man, Jeftic Dejan?

17       A.   No.

18       Q.   Continuing:

19            "His unit consisted of approximately 30 soldiers.  Two to three

20    days later, Lukic Milan arrived in Visegrad with his unit of approximately

21    15 men.  Fifteen more men joined this group, including Vasiljevic Mitar,

22    Lukic Sredoje, Vujicic Niko," and it says "a brother of Lukic Milan,

23    Knezevic Mitar, Trifkovic Miroslav, aka Miki, Markovic Mladen, Tanaskovic

24    Nenad, Gorazdak," and that's a nickname.  "When they arrived, the plunder

25    and destruction of houses began."

Page 2667

 1            Sir, isn't that a more accurate account of how the problems in

 2    Visegrad began?

 3       A.   I didn't understand your question.

 4       Q.   My question is:  Isn't that a more truthful account of how the

 5    problems in Visegrad began in the spring and summer of 1992?

 6       A.   In my opinion, no, because the Uzice Corps was not that small for

 7    one man to be able to call it and bring it to Visegrad.  It numbered

 8    3.000.  That is not a serious statement.  Now, anybody who attended the

 9    media was quite clear.  People knew in Visegrad and the surroundings that

10    not only Visegrad, but downstream - Bajna Basta, Zvornik, and all the

11    other places - that they were threatened with a catastrophe in case of the

12    waters being released, or that Murat Sabanovic should release the waters

13    from the reservoir of the hydroelectric power station.  So I took that to

14    be very serious, and anybody who saw what water could do and what water

15    did when a part of it was released from the reservoir would have been

16    quite clear as to why the Uzice Corps had been sent to Visegrad, because

17    there was the serious threat that Murat would release the waters from the

18    reservoir and that this would cause a material and human and ecological

19    catastrophe.  So in my opinion, that was the only reason for which this

20    was done, and straight away, afterwards -- actually, they didn't stay on

21    too long.  They left soon afterwards.

22       Q.   VGD23, let's go back to the convoy.  Was anybody -- was any of the

23    Muslims -- were any of them hurt on their trip to Olovo?

24       A.   At the time, the passengers got off, got out.  That is to say,

25    when we had reached our destination, the line -- at Sokolac, we were given

Page 2668

 1    a guide, two guides, and they were in the first bus with me.  And when we

 2    arrived at our destination point, it was a large space, an open space

 3    where the vehicles were turned around, and the people started getting out,

 4    off the buses and off the trucks.  So at that point, from the elevated

 5    areas -- from the hills, surrounding hills, shooting started from

 6    different weapons, and the targets were the buses and trucks.  The

 7    passengers from the convoy who had already got off laid down on the

 8    ground, on the grass and on the road, and we, under fire, managed to pull

 9    out towards -- as I was in the first bus.  Later on, I wasn't able to get

10    into the same bus, the first bus, but I boarded the last bus afterwards.

11       Q.   How many women, children, and elderly died on this event?

12       A.   From the injuries sustained, two people died.

13       Q.   I want to read you a portion of that statement of someone who was

14    on that bus, I will ask you at the end of it, is this not a more accurate

15    description of what happened.  "In mid-June of 1992, during the ethnic

16    cleansing of Visegrad and surroundings, [redacted] and others escorted

17    six buses and two trucks with Muslims leaving the area.  The convoy

18    stopped near Olovo and some of the Bosniaks tried to run, run away into

19    the woods.  The escort of Bosnian Serb nationality started shooting and

20    one woman and a child were killed while another child was wounded."  The

21    witness then says they saw you, [redacted], Milan Lukic, Sredoje

22    Lukic --

23            JUDGE HUNT:  Mr. Groome, [redacted]

24    [redacted].

25            MR. GROOME:  I'm sorry, Your Honour.

Page 2669

 1       Q.   Dragan Tomic, and Nenad Tanaskovic.  You five men were the men who

 2    were shooting at these people isn't that, in fact, what occurred on that

 3    day when you escorted these people out from Visegrad?

 4       A.   That's not true.  None of that is true.  I see no reason why they

 5    would not confirm my statement, Asim Nuhanovic, Sevala Veletovac I think

 6    the surname was, Hecimovic, a neighbour whom I knew.  Hamdo was the

 7    father's name of this Hecimovic man, I can't remember his first name.  I'm

 8    quite certain that they would confirm my statement and not the one you've

 9    just read out.

10       Q.   Were the people that I mentioned, were they present at this

11    convoy?

12       A.   I say with full responsibility that none of the people that you

13    read out were.  Dragan Tomic only in Visegrad gave me the task of -- gave

14    me this assignment and stayed in Visegrad.  Now, as to the others that you

15    mentioned from the list you read out, I say with full responsibility that

16    none of them was in the convoy nor anywhere near the convoy.

17       Q.   Do you know Behija Zukic?

18       A.   I do.

19       Q.   How do you know her?

20       A.   I know her from secondary school.

21       Q.   Do you know that she was killed?

22       A.   No, I don't.  I don't know that.

23       Q.   Do you know what car she drove?

24       A.   I don't know.

25       Q.   I am in possession of a statement from July of 1992 which,

Page 2670

 1    although it does not claim that you killed Behija Zukic, it said that you

 2    were the person who ordered the murder of Behija Zukic.  Is it a fact that

 3    you ordered the murder of Behija Zukic?

 4       A.   That's not true, nor would I ever be able to give anybody such an

 5    order.  That's -- just a normal person could not even think of doing

 6    anything like that let alone -- that's what I think.

 7       Q.   Were you ever present on the bridge in Visegrad when there was a

 8    shooting and some Muslims were injured?  Were you ever present during

 9    that?

10       A.   I was never present, not only on the bridge but anywhere else, at

11    some other place.

12       Q.   Do you know somebody by the name of Ibrasim Kesmer?

13       A.   Ibrisim?

14       Q.   Yes.

15       A.   What about the surname?

16       Q.   Kesmer.

17       A.   No, I don't know that.

18       Q.   I'm in possession of a statement which alleges that --

19            JUDGE HUNT:  Mr. Groome, how long do you think you are going to

20    be?

21            MR. GROOME:  I would imagine about 20, 25 minutes, Your Honour.

22            JUDGE HUNT:  Well, Mr. Domazet, what is the problem with this

23    witness?  I was only just told that you had hoped to get him back to the

24    former Yugoslavia this afternoon.  Can he be brought back later?

25            MR. DOMAZET: [Interpretation] He is due to leave tomorrow morning.

Page 2671

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Page 2672

 1            JUDGE HUNT:  I understand that.  All I'm saying is:  Can he be

 2    brought back at the end of next week or some other time?

 3            MR. DOMAZET: [Interpretation] I think he can.  If necessary, he

 4    can come.

 5            JUDGE HUNT:  Well, if the cross-examination can be concluded, and

 6    on a Friday afternoon, it is very unfair to ask the crew here to stay on

 7    for what could be, despite Mr. Groome's estimate, a very long time.

 8            So I'm afraid you'll have to come back later to conclude your

 9    evidence.  I regret that we can't finish it today.

10            MR. DOMAZET: [Interpretation] Your Honour, could we ask the

11    witness, while he is here, two things:  Whether he absolutely must leave

12    tomorrow, which means that he would have to come back, or can we ask him

13    if he could defer travelling and stay until Monday, and perhaps we could

14    continue him on Monday.  Perhaps it's a bigger problem for him to go and

15    come back.  So may we ask him that?

16            JUDGE HUNT:  Yes, certainly.  It's up to the witness.  I don't

17    propose to order him to do one thing or the other.

18            Which is more convenient, sir?

19            THE WITNESS:  [Interpretation] Well as I am here, perhaps it would

20    be better for me to stay on until Monday and to continue on Monday so that

21    we complete the examination.

22            JUDGE HUNT:  That's the best way of dealing with it, we'll deal

23    with it that way.  We'll adjourn now until 9.30 on Monday morning.

24                          --- Whereupon the hearing adjourned

25                          at 4.03 p.m., to be reconvened on Monday

Page 2673

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